Tips for Paralegals and Litigation Support Professionals

Sean O’Shea: Tips for Paralegals and Litigation Support Professionals – December 2020

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12/1/2020: Compare Excel spreadsheets for differences
Macro to see if two worksheets in the same Excel file have any text that differs.

12/2/2020: Tracking the Origin of an Email
You can use Google Toolbox’s Messageheader to analyze and email header and find the IP address of the author.

12/3/2020: Certificate for Destruction
The NIST Guidelines for Media Sanitization, NIST Special Publication 800-88, discussed in the Tip of the Night for August 9, 2020, includes a Certificate of Sanitization that you can use to verify that data has been completely removed from a storage device.

12/4/2020: Spreadsheet Compare
Don’t miss that MS Office comes with a tool named Spreadsheet Compare.   It can be used to not only detect differences between two workbooks, but also analyze each file and find where formula, macros, and edit protection are present.

12/5/2020: Add Password Protection to Multiple PDF Files
You can set up an action in FoxIt Phantom.

12/6/2020: Password Protect Multiple Excel files
I successfully tested vba code to add a password to multiple Excel files.

12/7/2020: UK Waiting to See If It Is Adequate . . .
After Brexit is finalized on 12/31/2020, the UK will have to obtain an adequacy decision in order for data to be transferred from the European Union to the UK.

12/8/2020: Remove all Non-AlphaNumeric Characters Including Spaces and Periods
A function which remove spaces and periods as well as all characters other than letters or numbers.

12/9/2020: Viewing Non-Printable ASCII Characters
ASCII text can contain non-printable characters which will not be visible when you open a text file in NotePad.  

12/10/2020: Using Facebook to Transmit PHI Violates VA Rules
A Court found that a VA doctor’s failure to use encryption to transmit PHI was substantial evidence supporting his dismissal.

12/11/2020: PowerShell Script to compare the hash values of multiple files

12/12/2020: Rhode Island Makes It Easier to Get an Expert’s Documents
The Rhode Island Rules of Civil Procedure have been amended so an opposing party can subpoena  any documents and materials relied upon by an expert.

12/13/2020: Facebook E2EE
Facebook can be set to use end-to-end encryption, but does not use it by default as WhatsApp does.

12/14/2020: Generate Letter Suffixes in Excel from AA to ZZ
Use this formula:

=CHAR(65+TRUNC((C2-1)/26)) & CHAR(65+MOD(C2-1,26))

. . . with a number helper column that begins at 1 for AA

12/15/2020: Data Processed Under EU Whistleblower Law Covered by the GDPR
Last year, the European Parliament passed EU Directive 2019/1937 in order to protect people who report breaches of EU law.  This new whistleblower law requires that personal data processing done pursuant to the reporting of EU law violations comply with the General Data Protection Regulation.

12/16/2020: New York State Court Rules on Third Party ESI Request
Parties requesting ESI from non-parties may have to cover to the costs of business operations disruptions which are quantifiable.

12/17/2020: Redfern Schedules
In arbitration, a Redfern schedule is a table that is often used to list a party’s document requests.  

12/18/2020: Excel MOD Formula to Determine Your Odds and Evens
Excel’s simple MOD formula will let you know if numbers in a column are odd or even.

12/19/2020: Excel formula to look up the closest number in a range

12/20/2020: Notes on Abbreviations
The abbreviation ‘App.’ may be used in a filing title for ‘Appeal’ or ‘Appellate’, but table BT1 of the Bluebook, which gives abbreviations for words used in the titles of court documents, specifies that ‘App.’ be used for ‘Appendix’ and ‘Appeal’ be spelled in full.

12/21/2020: Digital Services Act and Digital Markets Act
The European Union announced the Digital Services Act and Digital Markets Act this month.  The proposed legislation is designed to prevent Big Tech from competing unfairly with small businesses.

12/22/2020: ABA Opinion on Lawyers Practicing Remotely
Last week, the American Bar Association issued its Formal Opinion No. 495 on Lawyers Working Remotely, which endorses the position that attorneys can remotely practice law in a jurisdiction in which they are licensed, while they are located in a different jurisdiction. 

12/23/2020: Collecting Message App Data
Collecting data from messaging apps can be difficult, but specialized applications exist to create snapshots of text messaging services which will index the text of the messages and allow it to be searched.

12/24/2020: Armesto Schedules
Armesto schedules differ from Redfern schedules in that they use a vertical form and based on the objections and requirements of the International Bar Association’s Rules on the Taking of Evidence in International Arbitration.

12/25/2020: terminate individual processes of programs
taskkill /PID #### /F

12/26/2020: M.D. Ala.: E-Discovery Consultant’s Database Review Insufficient to Certify Class
A Court ruled that an e-discovery consultant could not rely on a database field instead of court orders when ascertaining class members for class certification.

12/27/2020: New York Appellate Division: No Dismissal for Loss of ESI Stored for 7 Years in a Safe
“Although the relevant hard drives appear to have been negligently forgotten in a safe in the law firm of plaintiff’s attorney for approximately seven years, there does not appear to be a dispute that the hard drives of plaintiff and her husband were imaged by a vendor for the purpose of preservation. . .The court therefore did not abuse its discretion in refusing to dismiss the amended complaint as a spoliation sanction.”  Miller  v. Miller, No. 761 CA 20-00203, 2020 N.Y. App. Div. LEXIS 8153 at *9 (4th Dep’t Dec. 23, 2020).

12/28/2020: Don’t Let Your SSID Be Your ID
The name of your wifi network is your SSID – the Service Set Identifier.  Be sure that your SSID name doesn’t refer to the manufacturer of the router; the name of your internet service provider; or your family name or home address.

12/29/2020: Be Sure to Change Your Router’s Default Password
If someone gains control of your router, they can execute a pharming attack.  A pharming attack will re-direct your internet traffic to a different DNS server (domain name server) that will translate web address names into the IP addresses of sites set up for malicious purposes. 

12/30/2020: Internet Browser Requirements for RelativityOne
The default versions of Firefox and Safari will block some pop-up windows for RelativityOne.

12/31/2020: Load and Run times in RelativityOne
RelativityOne will categorize all queries which take longer than 2 seconds as ‘long-running queries’.  

RelativityOne categorizes all queries which take longer than 2 seconds as ‘long-running queries’.  

Sean O'Shea on Email
Sean O'Shea
Litigation Paralegal
Sean O’Shea began working as a litigation support analyst at Brobeck, Phleger & Harrison LLP in 1998, near the dawn of the electronic discovery era. From assisting clients with the implementation of information governance policies, to conducting electronic presentations for attorneys at trials, he has been involved in all aspects of litigation support work. Sean is a Relativity Certified Administrator and an ACEDS Certified E-Discovery Specialist. He’s currently employed as a litigation paralegal in New York City, and continues to advise attorneys on legal technology. Look for a new tip on each night on

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