Plaintiff cited several errors and irregularities in e-mail production, including that the date and timestamps on every e-mail had been modified to reflect the dates the production was compiled, rather than when sent; that many e-mails were missing attachments; that documents were allegedly modified after notice of the litigation; no retention or preservation efforts after the lawsuit was filed; and no litigation hold communicated to employees. Furthermore, evidence established that relevant e-mails might be stored on personally-owned home computers and in personal e-mail accounts of employees. Magistrate Catoe ordered the production of work and personally-owned home computers for nine employees, establishing a detailed 20-step protocol to control the scope of the forensic examination and to protect claims of confidentiality and privilege. Koosharem v. Spec Personnel, No.08-583, 2008 WL 4458864 (D.S.C. Sept. 29, 2008).
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