Answer to Question 1
At a minimum, an additional workstation will be required for the networked office, whether the new user is a lawyer, paralegal, or secretary. The software requirements may vary depending on the position. For example, it will be important for the attorney and the paralegal to have access to any legal research programs or Internet services in use.
Answer to Question 2
The initial step in the discovery process is determining what documents are needed. It is also necessary to determine their location, their value to the case, their format, and the costs of retrieving them. All of this information is needed to prepare a proper discovery request. The request must also be tailored to the rules of the jurisdiction. Discovery of documents usually starts 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. A good starting point is to submit an interrogatory asking the party to identify key persons who might have created or received any relevant electronically stored information. Exhibit 13.4 is a portion of sample interrogatories related to the discovery of electronic data. With the information from the interrogatories, the next step in obtaining information that may lead to existing or destroyed ESI is using a Rule 30 deposition.
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