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Transcript of Ethical EDD
ETHICAL EDDA Guide To Making Ethically Sound Decisions In Handling EDD Processing
ETHICAL EDD – Copyright 2010 ADS – For internal use on ACC website only. May not be distributed.
To provide a framework that will empower legal advisors to make ethically sound decisions related to the handling and processing of ESI.
Ethical focus is on the following responsibilities• Competence • Diligence• Promptness • Accuracy• Defensibility • Expeditiousness • Efficient Use of Resources
Scope We will also address topics that should be
considered when making decisions at various stages of EDD.
PURPOSE
ETHICAL EDD – Copyright 2010 ADS – For internal use on ACC website only. May not be distributed.
AGENDA Who is defining the landscape? A Paradigm Shift – Embracing the
Openness Jurisdictional Differences – A quick
example EDRM – We’ll look at the stages & point
out choices that represent potential ethical danger zones Identification - Lit Hold & IT Policies – Accurate,
Defensible, Prompt? Production Requests – Crafting & Responding - Universe of Data – How defensible is your data
manifest? Pre-Processing – Is your culling methodology accurate
& defensible? Bulk Tagging – Combining Tools with Competence &
Diligence De-duping – Refresher; Is Global “global”?; Is re-duping
defensible? Clustering & Searching – Competence & Accuracy
ETHICAL EDD – Copyright 2010 ADS – For internal use on ACC website only. May not be distributed.
PREFACE
I am a Consultant; not a litigator. E-Discovery in the courtroom
represents “…a rapidly evolving situation...”
I am not here to lay down Bright Line rules.
I’m here to talk about general principles.
ETHICAL EDD – Copyright 2010 ADS – For internal use on ACC website only. May not be distributed.
WHO IS SHAPING THE LANDSCAPE?
Consider the experience of those shaping the landscape... The litigator’s Electronic Discovery landscape is largely
being shaped by Magistrate & District Court Judges. They have no practical litigation experience with E-
Discovery yet they are the ones making the rules and sanctioning firms.
ESI didn’t exist when they were attorneys. They are creating rules with very draconian penalties
for failure to follow them. All of this comes with huge costs.
Example: A Magistrate Judge presiding over the discovery hearings
on a construction case involving over 40 parties & non-parties ruled that 38 duplicate copies of the hard drives containing one party’s production request were to be produced and delivered to the other 38 parties within 24 hours. When counsel pointed out the practical issues regarding the time it would take to do this, the Judge effectively said “I don’t care! Do it!”
ETHICAL EDD – Copyright 2010 ADS – For internal use on ACC website only. May not be distributed.
ETHICAL OBLIGATION VS. PROFESSIONAL RESPONSIBILITY?WHAT CAN YOU DO? As a practical approach, you need to
present to the judge the EDD strategy and methodology utilized for your case in a way that justifies the soundness of your decisions, obviates your forthrightness, demonstrates your understanding of the technology involved and your adherence to best practices.
It could be argued that the legal community involved in litigating ESI cases has an obligated duty to guide the educational process of the judges charged with making the rules.
ETHICAL EDD – Copyright 2010 ADS – For internal use on ACC website only. May not be distributed.
EMBRACING THE OPENNESS…
A PARADIGM SHIFT Litigators are not trained to share
information. They are trained to give the absolute minimum they possibly can.
In EDD, the courts are pushing a different paradigm regarding sharing (and not resorting to the Judge to make a ruling).
Sedona talks about being as open as you can possibly be. Doing the opposite can get to be very expensive.
In any case, once the Judge finds out you’ve been hiding, they are going to force you to open up.
ETHICAL EDD – Copyright 2010 ADS – For internal use on ACC website only. May not be distributed.
COMPETENT? DILIGENT?
JURISDICTIONAL DIFFERENCES Jurisdictional differences play a large part The rapid pace of rulings and lack of accepted
guidelines has resulted in extreme differences in the rules among jurisdictions.
“...decisions in adjacent jurisdictions are diametrically opposed to one another...”
Example: In the case of inadvertently produced privilege documents; does the producing party have a duty to report? DC and MD are neighbors but the rules in
each jurisdiction are exactly opposite of one another.
One says that attorneys have a “professional responsibility & duty to report” inadvertently produced privilege documents; the other says it is not required.
ETHICAL EDD – Copyright 2010 ADS – For internal use on ACC website only. May not be distributed.
EFFICIENT? DILIGENT? COMPETENT?
ARE YOU ON THE SAME PAGE AS OUTSIDE COUNSEL?
How well do you understand the process, methodology and technological tools at your disposal?
You have the professional responsibility to not only understand the capabilities; but also to have the requisite expertise and wherewithal to efficiently, economically, accurately and defensibly leverage the technology and resources available to you.
Is your outside counsel also following this mindset? Where do differences in methodology and expertise exist between your team and outside counsel? How would you answer this question if posed in Court?
ETHICAL EDD – Copyright 2010 ADS – For internal use on ACC website only. May not be distributed.
EACH STAGE REPRESENTS RISK
The goal of EDRM is to develop guidelines and standards for e-discovery consumers and providers.
Should We Self Collect? Do We Cull Internally?
Chain of
Custody?
Domain Filtering
?
Bulk Tagging
?
Subjective or
Deterministic?
How Inclusiv
e?
Near Dupes?
Omissions?
Data & Custodia
n Mapping?
Do We Have It
All?
Duplicates
Included?
Production
Format?
ETHICAL EDD – Copyright 2010 ADS – For internal use on ACC website only. May not be distributed.
DILIGENT? DEFENSIBLE? ACCURATE? COMPETENT?
IDENTIFICATION- A Hypothetical Example…
Self-Collection – Your thoughts?
Under what circumstances should you allow custodians or internal staff to identify or self collect relevant data?
Judge Scheindlin recently categorized the practice of self-collection as an act of gross negligence. Other judges have made similar assessments.
ETHICAL EDD – Copyright 2010 ADS – For internal use on ACC website only. May not be distributed.
Humor Break: In the interest of openness and sharing; welcome to my world…
Used by permission of Tom Fishburne. www.tomfishburne.com
ETHICAL EDD – Copyright 2010 ADS – For internal use on ACC website only. May not be distributed.
IDENTIFICATION - UNIVERSE OF DATADEFENSIBLE? ACCURATE? EFFICIENT?
ETHICAL EDD – Copyright 2010 ADS – For internal use on ACC website only. May not be distributed.
DEFENSIBLE? ACCURATE? EFFICIENT?LITIGATION HOLD: Identification &
Preservation Subjective vs. Deterministic practices
Subjective - Users isolate and / or retain documents “related to X” Is the identification of relevant documents being left
up to each custodian? How is the accuracy of their interpretation and
actual execution being monitored? Without knowledge of the case, how can a user
decide what is relevant? Deterministic - Objective process that uses very
specific rules to determine whether a document meets a particular criteria. Identify & preserve all email with To/From/CC/BCC
containing specified domains and email addresses Document Management Systems - Identify
documents that meet specified content or custodial criteria.
ETHICAL EDD – Copyright 2010 ADS – For internal use on ACC website only. May not be distributed.
DEFENSIBLE? PROMPT?
LITIGATION HOLD: Data Mapping & Tape Backups
Data Maps - Identifying Data Sources in Advance Prepare data maps based on custodians most likely to
have data of interest in any litigation Prepare a subject matter map that consists of specific
data most likely to be of interest in litigation Identify present and historical data sources including
legacy data Archive data - identify & catalogue your physical
sources* of data (*including any dark storerooms full of unmarked tapes)
Tapes – ***A Special Note*** Expect the courts to be less likely to accept financial
burden or inaccessibility as a reasonable argument against collecting from tape backups. Tools now exist that can cheaply catalogue and search tapes.
Several Magistrate Judges have been given live demonstrations of tools that can index & search tapes quickly & cheaply. Expect them to be less likely to accept inaccessible as a reasonable argument.
If there is no legal reason to retain them; get rid of them!
ETHICAL EDD – Copyright 2010 ADS – For internal use on ACC website only. May not be distributed.
DEFENSIBLE? PROMPT? DILIGENT? COM
PETENT?LITIGATION HOLD: The Power of
Policy Do you have existing policies that define how
custodians are to manage their data and data-containing devices?
Email? Are users responsible for managing the size of their
email store files? Are they allowed to use offline storage files?
Lotus Notes: Do users detach large attachments from email in order to manage the size of their mailbox? How is this resolved/identified when the data is collected?
Are users allowed to access non-work email accounts (gmail, Yahoo, etc.) from work computers?
Distribution Lists - Custodians may receive email that is sent to distribution lists (DLs) of which they are a member. Searches for just the custodian’s email address may result in these messages being excluded from the collection.
Is this membership tracked? Does it include the dates they were added/removed from
the DL?
ETHICAL EDD – Copyright 2010 ADS – For internal use on ACC website only. May not be distributed.
DEFENSIBLE? PROMPT? DILIGENT? COM
PETENT?LITIGATION HOLD: The Power of
Policy BlackBerry & Other PDA devices
What is the policy regarding non-email communications and data? SMS (Text) Messages MMS (Multimedia Messaging Services) Messages - RIM only
stores the text of these messages. Are the images relevant?
PIN Messages (Personal Identification Number) - Is your BB server configured to store and retain PIN messages? Are PINs of users stored along with the dates of any device or configuration changes that would result in a new PIN?
IM (Instant Messaging) - Is your BB server configured to store and retain IM data?
Notes, address books, mobile documents, photos - Is your system configured to sync and retain this data?
If not synchronized, what differences exist between the device and the server versions of the address books? Did you compare aliases to see if custodians utilized other forms of communication under different names?
ETHICAL EDD – Copyright 2010 ADS – For internal use on ACC website only. May not be distributed.
ACCURATE? COMPETENT?
PRODUCTION REQUESTSResponding to Production Requests Courts expect attorneys to be as open and a generous
with information as they can be. EDD is a conundrum for many litigators because it is 180
degrees from what a judge would expect you to do with paper. They WANT you to volunteer information and they can get very angry with you if you don’t.
Crafting Production Requests Judges want you NOT to hide anything. "They want you to construe ESI requests as broadly as
possible. Narrow requests piss them off. In paper discovery, the narrow request is normal, but in Electronic Discovery, Judges don’t want to see that."*
* Senior Counsel, New York City Law Department
ETHICAL EDD – Copyright 2010 ADS – For internal use on ACC website only. May not be distributed.
DEFENSIBLE? COMPETENT? ACCURATE? DILI
PRODUCTION REQUESTS – IMPORTANT!
1. Be careful to be open and “avoid being under inclusive in what you are producing. Don’t ‘go lawyer’ on deciding how inclusive to be.”
2. (This is even harder.) You have to really know what you have and what you’ve given over.
Example: In a recent case with one of my clients, opposing counsel opposed a motion for summary judgment regarding signed releases. The argument was that because they didn’t have any claims at the time of the release, they left the space blank. They didn't fill it out and claimed that they couldn’t have detailed any claims because zero claims existed at the time the release was signed.
In the privilege log however, there were nearly 300 docs pertaining to the large list of claims and damage calculations that predated the date they signed the release.
ETHICAL EDD – Copyright 2010 ADS – For internal use on ACC website only. May not be distributed.
VOLUME OF DATA – You should know this… How much data do you have? There is a big difference between the amount of data
collected and the amount of data you will have after culling 50 Gb of email will result in a lot more reviewable data than
a 300 Gb forensic image taken from a hard drive. Why? Forensic images include system files, programs, unused
drive space and deleted files. A 300 Gb image may equate to only 20 Gb of Reviewable ESI to be processed once it has been analyzed.
Collected Email data is, in essence, pre-culled ESI. 50 Gb = 50 Gb.
1 Gigabyte (Gb) of Reviewable ESI Approximately 70-100K pages About 25-30 bankers boxes
1 Terabyte (Tb) = 1024 Gb of Reviewable ESI Approximately 70-100 Million pages Approximately 25,000- 30,000 bankers boxes
EFFICIENT RESOURCE USAGE? PROMPT?
DILIGENT? COMPETENT?
ETHICAL EDD – Copyright 2010 ADS – For internal use on ACC website only. May not be distributed.
CULLING METHODS De-mystifying “De-NIST-ing”
The NSRL List (also called the NIST list) list can be used to eliminate known system files based on their digital signature.
The list is a collection of digital signatures of known, traceable software applications. It is updated regularly.
Culling Tools – In house or use a vendor? There are several culling tools available for “Do It
Yourself” culling. Consider the following when deciding if in house culling
is right for you: Who is going to be using the program? IT or dedicated staff?
Who is managing the in house collections? Are they qualified to handle their own evidence?
Chain of custody – Is client capable of documenting this? How frequently will culling be needed? Compare risk vs. cost savings
DEFENSIBLE? ACCURATE? COMPETENT?
ETHICAL EDD – Copyright 2010 ADS – For internal use on ACC website only. May not be distributed.
CULLING- A Hypothetical Example…Culling by Domain In pre-processing, it is decided to narrow
the scope of your data through the use of email domain culling. This allows you to eliminate email from non-work sources, solicitation/spam, weekly industry newsletters, fantasy sports newsletters, etc. What is the obligation to share the list of
excluded domains with opposing counsel? A pornography website is among the excluded
domains. The email was identified among the data for a prominent employee. What is the responsibility to those you represent?
DEFENSIBLE? DILIGENT?
ETHICAL EDD – Copyright 2010 ADS – For internal use on ACC website only. May not be distributed.
DEFENSIBLE? ACCURATE? COMPETENT?
Avoid falling victim to the risks associated with under-informed or improper use of “bulk coding” options of pre-processing software applications. Domain filtering is a useful tool in categorizing
and prioritizing documents but it does not negate the responsibility to review the documents.
Clustering or near dupe applications with categorizations stating “you don’t have to review those records...” or similar.
Context is relevant. Since context can differ for even Hash level duplicates, you should not blindly code exact duplicates identically. The context may alter that categorization, so it is critical to at least review the differences related to the context of duplicates.
Avoid the temptation of the Easy Button.
PRE-CULLING/REVIEW – BULK TAGGING
ETHICAL EDD – Copyright 2010 ADS – For internal use on ACC website only. May not be distributed.
DEFENSIBLE? ACCURATE? COMPETENT? DILIGENT?
Bulk Tagging - Non-Responsive Documents
Is an MD5 Hash matching duplicate of a non-responsive document also non-responsive?
The file “Take This Job And Shove It.MP3” is found among thousands of other songs in a users iTunes library. An exact duplicate of the file sits alone in a disgruntled former employee’s desktop folder named “For The Jerks”. The former employee is among several involved in a IP theft case. Are both files equally non-responsive?
BULK TAGGING- A Hypothetical Example…
ETHICAL EDD – Copyright 2010 ADS – For internal use on ACC website only. May not be distributed.
DE-DUPLICATION - Hash values -You should know this…
Hashing uses an algorithm to compute a unique value for a file
Even the most minute difference between 2 seemingly identical files will result in completely different hash values
Hashes are deterministic – Hash algorithms will generate the same hash value for any static file every single time.
Hash values appear in a normalized, hexadecimal format.
Examples of 32 digit MD5 hash values: The quick brown fox jumps over the lazy dog Hash Value: 9e107d9d372bb6826bd81d3542a419d6 The quick brown fox jumps over the lazy dog. Hash Value: e4d909c290d0fb1ca068ffaddf22cbd0
Numerous acceptable algorithms exist. Examples include:
MD5 SHA-1 SHA-256
DEFENSIBLE? ACCURATE? COMPETENT?
ETHICAL EDD – Copyright 2010 ADS – For internal use on ACC website only. May not be distributed.
DE-DUPLICATION – A Hypothetical Example… De-duplication – Review Strategies Global de-duplication will result in fewer
documents to review. However, it can hinder the review team’s understanding of context as it pertains to the custodians. Could a standard de-duplication policy
be used in every case? How much of a part does the expense
of review play vs. understanding the context?
What other variables should be considered?
EFFICIENT? PROMPT? DEFENSIBLE? ACCURATE? COM
PETENT?
ETHICAL EDD – Copyright 2010 ADS – For internal use on ACC website only. May not be distributed.
DE-DUPLICATION – Another Hypothetical Example… De-duplication – Production Assume that you globally de-dupe in
order to reduce review costs. When it comes time to produce your
documents, do you produce the globally de-duplicated set, a vertically de-duplicated set, or all of the data (no de-duplication)?
A recent ruling resulted in sanctions when a party produced a globally de-duplicated set of documents. The issue related to the order in which certain key custodians’ data was compared to that of other custodians.
EFFICIENT? DEFENSIBLE? ACCURATE?
ETHICAL EDD – Copyright 2010 ADS – For internal use on ACC website only. May not be distributed.
CLUSTERING – Early Case Assessment (ECA)Concept Based Clustering
Compares documents based on actual content
Similar documents can be grouped together to increase review efficiency Groups of similar, non-relevant documents can be
de-prioritized or possibly excluded Groups of similar, specialized documents can be
foldered for review by experts or specific members of the review team
Clustering is related to searching Many clustering technologies are language
independent Some technologies allow for user directed*
clustering *We’ll cover this further when we discuss searching
EFFICIENT? PROMPT? DEFENSIBLE? ACCURATE? COM
PETENT?
ETHICAL EDD – Copyright 2010 ADS – For internal use on ACC website only. May not be distributed.
SEARCHING – A Real World Example… Searching - Keyword Search Request
Received A firm submitted a search request that
included the names of several large organizations. Among the requested terms was “Ernest & Young”. Based on the written discovery request, which mentions Ernst & Young, it is obvious that the intent was to search for “Ernst & Young”. A member of your team notes this spelling error.
Do you run the search as instructed or do you modify the spelling? What if the error is discovered after processing many of the documents, or mid-way through your review?
DEFENSIBLE? ACCURATE? COMPETENT?
ETHICAL EDD – Copyright 2010 ADS – For internal use on ACC website only. May not be distributed.
SEARCHING: BASIC TYPES AND DIFFERENCES
Standard Boolean Operators AND, OR, NOT, W/x Wildcards, Fuzziness, Stemming
Quality of results can vary Overbroad results from use of “kitchen sink” strategy or inclusion of over-common terms Missed documents due to lack of research when devising search strategy – Initial search terms will lead to better search terms! Take advantage of “sampling” to improve quality of search terms
Many vendors offer consulting services to aid in improving the efficiency of key word searching.
Key Word Searching – A Quick ReviewConcept SearchingSearchable vs. Non-Searchable DocumentsTREC & EDRM
ACCURATE? DEFENSIBLE? COMPETENT?
ETHICAL EDD – Copyright 2010 ADS – For internal use on ACC website only. May not be distributed.
SEARCHING: BASIC TYPES AND DIFFERENCES
Two primary approaches are generally used Guided and Unguided Taxonomies (classifications) Both create “clusters” of similar or related documents
Guided Taxonomies utilize user or expert created “guides” to help categorize documents that share similar concepts.
Industry or case specific terms can be clarified to ensure that certain words are properly interpreted based upon context. E.g. The term “option” could be categorized with “stocks”, “compensation”, “price”, “market” and similar words to help distinguish it from “option” used in reference to a choice.
Unguided Taxonomies identify concepts based upon the document collection
Allows user to identify related documents lacking specified keywords Identifies related concepts that may have been overlooked
Let’s take a look at an example on the next slide.
Key Word Searching Concept SearchingSearchable vs. Non-Searchable DocumentsTREC & EDRM
ACCURATE? DEFENSIBLE? COMPETENT?
ETHICAL EDD – Copyright 2010 ADS – For internal use on ACC website only. May not be distributed.
SEARCHING: BASIC TYPES AND DIFFERENCES
Unguided Taxonomies - Latent Semantic Analysis (LSA) Analyzes the co-occurrences of words in the
collection. Analysis resolves conditions wherein words have
multiple meanings or where multiple words share the same meaning
Considers relationships between words The concept “bicycle” would relate to the concept “vehicle” The concept “chain” would relate to the concept “bicycle” But
only where bicycle-related documents were concerned. Documents mentioning “restaurant chain” would not be
related, despite the presence of the term “chain” User could search for “bicycle” and get documents
discussing “helmets”, “pedals”, “tri-athalon” or “Schwinn” that DO NOT actually contain the word “bicycle”.
Key Word Searching Concept Searching - continuedSearchable vs. Non-Searchable DocumentsTREC & EDRM
ACCURATE? DEFENSIBLE? COMPETENT?
ETHICAL EDD – Copyright 2010 ADS – For internal use on ACC website only. May not be distributed.
SEARCHING: BASIC TYPES AND DIFFERENCES
A Guided Approach Using the Bayesian Algorithm Built upon the theorem authored by Thomas Bayes (1702-
1761) Bayesian indexes can be used to identify documents that are
conceptually similar to a selected sample set of documents. The result is a category of similar documents that can then be
used to identify any additional documents that are likely of the same nature.
Email spam filters use Bayesian mathematics to calculate the probability that an email is legitimate based on the frequency of specific keywords found within them.
In Electronic Discovery applications, this technology can be used to create “hot” subsets of similar documents as a category to find “like” documents based on the subset.
Key Word Searching Concept Searching - continuedSearchable vs. Non-Searchable DocumentsTREC & EDRM
ACCURATE? DEFENSIBLE? COMPETENT?
ETHICAL EDD – Copyright 2010 ADS – For internal use on ACC website only. May not be distributed.
SEARCHING: BASIC TYPES AND DIFFERENCES
Searchable Documents All content within the file is available to be indexed & searched “Speaking” documents and text based files
Non-Searchable Documents Non-speaking documents such as binary files Encrypted or password protected documents Corrupt documents Image documents without any embedded text
These may be made searchable if OCR is generated for them
Are non-searchable documents addressed in your production requests?
Key Word Searching Concept SearchingSearchable vs. Non-Searchable DocumentsTREC & EDRM
DILIGENT? ACCURATE? DEFENSIBLE? COMPETENT?
ETHICAL EDD – Copyright 2010 ADS – For internal use on ACC website only. May not be distributed.
SEARCHING: BASIC TYPES AND DIFFERENCES
TREC1 “The Text REtrieval Conference (TREC), co-sponsored by the National Institute of
Standards and Technology (NIST) and U.S. Department of Defense, was started in 1992 as part of the TIPSTER Text program. Its purpose was to support research within the information retrieval community by providing the infrastructure necessary for large-scale evaluation of text retrieval methodologies.”
“Most of today’s commercial search engines include technology first developed in TREC.”
EDRM2 The EDRM Search Project is intended to create a normalized search schema that
will allow searches to be written in an application independent manner. It includes a broad array of search techniques; from Boolean to Concept / Clustering based methodologies.
The goal of EDRM is to develop guidelines and standards for e-discovery consumers and providers.
Technology and the landscape are both ever-evolving. Staying abreast of both is your professional
responsibility.1. http:// trec.nist.gov 2. www.edrm.net
Key Word Searching Concept SearchingSearchable vs. Non-Searchable DocumentsTREC & EDRM
DEFENSIBLE? COMPETENT?
ETHICAL EDD – Copyright 2010 ADS – For internal use on ACC website only. May not be distributed.
SEARCHING – A Hypothetical Example… Searching - Stemming Current tools allow stemmed searches to
eliminate unwanted word variations. For example, a search for the word “option” in a stemmed search would return options, optional, optionor, optionee, optionally, optioned, etc. In a back-dating case, would you allow opposing counsel to selectively eliminate variations that appear to be unrelated to stock options?
If yes, would you expect opposing counsel to be willing to provide a list of the excluded variations of the search term?
ETHICAL EDD – Copyright 2010 ADS – For internal use on ACC website only. May not be distributed.
ETHICAL EDDTopical Speaker: Joseph Derting, CFP, CCST, CCFA, iCA, CCA
Joseph Derting is a pioneer in the development and implementation of electronic discovery application processes. As Director of Consulting and Hosting Services at ADS, he works with clients from the onset of litigation through production.
Joseph’s industry contributions include: management of the conceptualization and development of EDD software applications; strategic consulting and providing technology-based evidentiary counsel; 8 years of managing electronic discovery processing; creation and implementation of test procedures for the five generations of EDD software; conceptualization and development of electronic discovery software training materials & methodology; and conducting on-site certification training programs in the use EDD software in nearly 70 litigation support offices around the U.S., U.K. and Canada.
Joseph has taught electronic discovery theory to over 200 professionals in Europe and North America, with more than 80+ training and speaking engagements to his record. He has been a featured speaker at numerous seminars and educational events. He is certified by Oregon State University in Computer Forensics and trained in the use and presentation of electronic evidence in Court; often appearing in U.S. District Court on behalf of clients. Recent Speaking Engagements (sample listing)
2007 FRCP Rule Changes & Effects on E-Discovery - Vendor Responsibilities - Portland, OR2008 Understanding Metadata CLE – Seattle, WA2009 Data Culling Methodologies CLE – Washington, DC2009 EDD to English: A Primer on Basic Terminology, Methodology & Practice CLE – Portland, OR2010 Bridging the Gap: Intermediate EDD Methodology & Practice CLE – Seattle, WA
2010Ethical EDD CLE - ACCA Southern California Chapter2010 Certifications
Certified discover-e Operator, discover-e TrainerCertified Forensic Professional – Oregon State UniversityConcordance Certified Software Trainer & FYI AdministratorCertified iConect Administrator Certified Clearwell Administrator
EducationB.A. Business Administration - University of Washington, 1988
AssociationsEDRM – Co-Lead – Probabilistic Hash Project, 2009-2010