Discovery of Electronically Stored Information

Discovery Deposition of a Adversary’s Electronic Files begins with Checklists.

Fact: In today’s world most documents and data are electronic. 90% of correspondence and data is stored electronically, not in file cabinets. Most financial and operating data is stored electronically and very little printed. Most external and internal correspondence is either e-mail or it is written on a computer, and the sender’s copy is kept electronically.

We offer the advice of a mentor in the format of a legal form checklists for use in the discovery process with an adversary.

At the present time two forms regarding discovery of electronic documents are available, please visit our main website for additional forms dealing with ESI.


  • DF-ELEC-3324 Deposition Checklist for eDiscovery of Entity’s Electronic Files and Data

    This is a checklist to use during a deposition to find out what kinds of electronic records exist and how they may be accessed. It is 26 pages of single-spaced deposition outline checklist, loaded with the ideas and questions that are vital to uncover what electronically stored information exists, and where it is located

    This is a “must-have” if you want to include electronic documents and data in your discovery. And who doesn’t today? Electronic discovery has become necessary because almost all documentary evidence today is stored on a computer. This electronic discovery checklist is good not only for depositions, but also for suggesting areas and items to include in your demand for production of documents or your interrogatories.

  • DF-ELEC-3304 Protocol Search Computers

    A checklist to use for discussions with adverse counsel about the mechanics of who will do what when and with what safeguards during an adverse inspection of computers. Although written from the viewpoint of the attorney asking for the physical inspection or download of electronic records, the checklist is equally valuable to responding counsel interested in ideas for protecting the client’s computers.