Case Document Entered on FLSD Docket Page of May Page2 Electronic documents and the storage media on which they reside contain relevant discoverable information beyond that which may be found in printed documents Therefore even where a paper copy exists we may seek ail documents in their electronic form along with information about those documents contained on the media We also may seek paper printouts of only those documents that contain unique information after they were printed out such as paper documents containing handwriting signatures drawings annotations highlighting and redactions along with any paper documents for which no corresponding electronic files exist Our discovery requests may ask for certain data on hard disks floppy disks 267and backup media used in your clients computers some of which data are not readily available to an orainary computer user such as deleted 225files and file fragments As you may know although a user may erase or delete a file ail that is really erased is a reference to that file in a table on the hard disk unless overwritten with new data a deleted file can be intact on the disk as any active file you would see in a directory listing With regard to electronic data created subsequent to the date of delivery of this letter relevant evidence is not to be destroyed and your clients are to take whatever steps are appropriate to avoid destruction of evidence In order to assure that you and your clients obligation to preserve documents and things will be met please forward a copy of this letter to all persons with custodial responsibility for the items referred to in this let RDC/clz cc Jack Goldberger Esq Micha Burman Esq Michael Pike Esq
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