Answer to Question 1
Kate should begin the process with interrogatories seeking information not only about current documents, but also about the party's retention policies and the items or types of items that may have been destroyed. They should include an interrogatory asking Synchromotive to identify key persons who might have created or received any relevant electronically stored information. Once these persons are identified, she should request Rule 30 depositions of persons who are knowledgeable about Synchromotive's information management system.
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Answer to Question 2
In some cases, critical data has been modified or deleted from documents produced in discovery, and dates of these modifications or changes may be very relevant and material. The metadata of these documents will usually show the dates of any changes. Qualified forensic experts can examine the original hard drive to determine if there were any changes or deletions of material. However, it is important to remember that each time a document is opened, the metadata changes. Therefore, in cases where forensic data collection is required, it is important to have an expert who can obtain the information without changing anything on the original storage media.
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