Sean O'Shea litigation tips.

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

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6/1/2020: When to use – ; – ; or —
A hyphen – to separate words.

An en dash – to separate ranges.

An em dash — in place of a colon, comma, or parentheses.

6/2/2020: DFIR – Digital Forensics and Incident Response
Digital Forensics and Incident Response (DFIR) is a term for the application of digital forensic techniques to cyber security.

6/3/2020: The Amcache registry and how to access it
Amcache is a registry hive on Windows operating systems which has information on applications that have been run on a PC.

6/4/2020: Parsing prefetch files
Prefetch files stored at C:\Windows\Prefetch can be analyzed to show which programs have been run on a Windows computer.

6/5/2020: Regex search for Month, DD, YYYY

6/6/2020: Input Method Editor
The Windows Input Method Editor will let you switch to almost any foreign language by clicking an icon in the system tray.

Input Method Editor

6/7/2020: New York Appellate Division E-filing Guidelines
The guidelines specifically state that, “PDFs that contain skeletal bookmarks (i.e. missing headings), minimal Table of Contents or no bookmarks will be returned for correction.”

6/8/2020: The 90 Second Test
A good brief should open by addressing the deeper issues at hand, and in 90 seconds make clear its primary point.  Premises making reference to facts should be quickly stated, and then a yes or no question should be asked so that only one answer to it appears to be possible.  Draw a conclusion after reviewing the issues in 75 words or less.

 6/9/2020: Security Orchestration, Automation and Response (SOAR)
Security Orchestration, Automation and Response (SOAR) refers to the use of automated workflows to facilitate responses to security incidents.

6/10/2020: Dealing with large Relativity workspaces on SQL Server
A SQL Server table for a Relativity workspace will take up approximately 50 GB of disk space for a million documents.  The SQL Server has RAM limits – the 2016 edition is limited to 128 GB of RAM.

6/11/2020: HDDs and SSDs
A SSD device does not include any moving parts.  It differs from a hard disk drive (HDD) which stores information on spinning disks.

         HDD                      SSD


6/12/2020: Crypto Sheriff
Crypto Sheriff is an online service which can help decrypt files that have fallen victim to a ransomware attack.   See:   The “No More Ransom” project helps identify keys needed for decryption.  It is a joint project of Europol, Kaspersky, McAfee, and the national police of the Netherlands.

6/13/2020: E.D. Cal.: Employees Taking Trade Secrets Must Cover Forensic Analysis of Their Electronic Devices
“Given that defendants have conceded improperly taking ExamWorks’ trade secrets and the court has found they did so intentionally, they have not overcome the presumption that as the responding party they must bear the expense of discovery, including the costs of the forensic expert.” ExamWorks v. Baldini, No. 2:20-CV-00920-KJM-DB, 2020 U.S. Dist. LEXIS 103366, at *44 (E.D. Cal. June 11, 2020)

6/14/2020: Nuix Workstation
In order to process Lotus Notes archives and OCR documents with Nuix Workstation you need to install additional software.

6/15/2020: Craig Ball on Forms of Production
For email, ask, “Can the form produced be imported into common e-mail client or server applications?”

6/16/2020: Excel TEXT Function to Display Date in Formula
=”Letter dated, “&TEXT(A2,”mm/dd/yyyy”)

6/17/2020: Semi-structured data
Semi-structured data is data that is not organized in a relational database, but which contains tags that separate elements of the data.   An object database uses semi-structured data.

6/18/2020: Garner’s Guide to Making Briefs More Persuasive: Tip 12 – Avoid one sentence issue statements
When writing an issue statement, don’t try to do it with one sentence, and certainly don’t begin with ‘Whether’ or another interrogative word.  An issue statement should follow a chronological order, and end with a pointed question.

6/19/2020: D.D.C.: Notice to Court of E-Discovery Search Problems Excuses 8 Day Delay in ESI Request Response
“Defendant also represented that it had modified the emails to provide Bates numbering. Thus, Defendant’s production of the emails did not ‘replicate[] the manner in which they were originally kept’ and Defendant was required to ‘label them to correspond to the categories in the request[.]’ Fed. R. Civ. P. 34(b)(2)(E)(i).  Defendant shall supplement its electronic discovery responses to comply with this requirement.”  Ronaldson v. Nat’l Ass’n of Home Builders, No. 19-01034, 2020 U.S. Dist. LEXIS 107436, at *27 (D.D.C. June 3, 2020).

6/20/2020: using Python in Windows
After you have installed Python on a Windows operating system, you can start the Python interpreter by entering Windows command prompt and entering the command ‘py’

6/21/2020: PATH System Variable
Windows 10 uses a PATH system variable to track the paths for programs that can been then be referenced in command prompt.  It can be set in System Properties on the advanced tab.

6/22/2020: Windows Recycle Bin $I and $R files
Inside a Recycle Bin you may find files which begin with either ‘$I’ or ‘$R’.  A file beginning with ‘$I’ will contain data about a file that has been deleted.  A file beginning with $R will contain the actual content of a file.

6/23/2020: Elasticsearch
Elasticsearch is an open source NoSQL database that Relativity Data Grid uses with the Audit application, which runs reports on user activity.

6/24/2020: Extracting Links for Multiple Documents in a Box Folder
You can get multiple links for documents in a folder on Box by reviewing the page source code.

6/25/2020: eDiscovery with Microsoft Teams
Teams chat messages are journaled with users’ Outlook mailboxes, so a shadow copy of these messages is included when one is prepared of email messages and other Outlook data.

6/26/2020: Macro to merge Word files
This macro will prompt you to select the folder with your source files.

6/27/2020: New York Court Rules Mandate E-Discovery Competency
The rules state that, “. . . counsel for all parties who appear at the preliminary conference must be sufficiently versed in matters relating to their clients’ technological systems to discuss competently all issues relating to electronic discovery.”

6/28/2020: Some States Qualify Duty of Technology Competency
New York’s professional rules modify comment 8 to Rule 1.1, to emphasize that attorneys have a duty to keep ESI secure.

6/29/2020: Excel formula to extract folder from file path
This method can be adjusted to pull any one of multiple folders in a file path.

6/30/2020: Sedona Guide for Judges
The month, the Sedona Conference released the third edition of The Sedona Conference Cooperation Proclamation: Resources for the Judiciary, Third Edition.  This guide makes seven principal recommendations for judges on how to handle electronic discovery in civil actions.

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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