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Electronic discovery (eDiscovery) refers to the discovery of electronic files in civil litigation or government investigations which deals with the exchange of information. eDiscovery is essentially the collection of a large volume of data from a large number of hard drives and/or other storage media. Typical files collected during eDiscovery investigations vary from emails, documents, databases, pdf, PowerPoints, etc. Having provided our electronic discovery services to numerous multinational corporations, as well as law firms, we have the necessary hardware, software and manpower to handle any ediscovery request. We are capable of processing terabytes of e-mail archives in a very short period of time using our state-of-the-art storage and processing servers. We possess enterprise-class forensic tools that eliminate travel to multiple locations to image computers or retrieve relevant documents from servers when applicable.

eDiscovery Collection, Processing & Production Services

This service is applicable to any litigation matter where electronic discovery production is necessary. According to the Federal Rules of Civil Procedure, the responding party must produce electronically stored information either in the form in which it is ordinarily maintained or in a form that is reasonably usable. Approximately 97% of all business records are stored electronically. Cyber Diligence, Inc. can assist you whether you are representing the defendant or plaintiff with processing and production of electronically stored information (“ESI”). 

Preservation and Collection:

  • Identify, preserve and collect relevant ESI in a forensically sound manner from computers, email and file servers, PDA, loose media, back-ups and archives as prescribed in the meet and confer.
  • Prepare chain of custody documentation.
  • Store ESI at Cyber Diligence’s evidence safe for safe-keeping.

Processing Review & Analysis:

  • Perform data processing of collected ESI, identification of certain file types agreed to in the meet and confer, culling out of systems files, de-duplication of ESI by custodian or matter, and key word searching.
  • Prepare list of file exceptions (password protected, encrypted and/or corrupt).   Decrypt password protected files utilizing government grade decryption hardware and software.


  • Performed at law firm or through Cyber Diligence’s hosting partners.
  • Identify documents to be produced in certain formats per requestor.
  • Review annotations of reviewers to determine if they are appropriate.
  • Create load files for various hosting/review tools.
We have a state of the art computer forensics lab equipped to process and search terabytes of data efficiently in preparation for counsel’s review.  Cyber Diligence uses the latest computer forensics hardware and software to process ESI accurately and efficiently with full audit documentation.  In addition, we have developed a detailed EDD playbook which addresses the challenges that litigation attorneys face:  a) sanctions due to spoliation, b) adverse inference, c) accuracy and completeness of the eDiscovery process, d) quality control and e) cost overruns.
eDiscovery Consulting Services

This service is applicable to any litigation matter where electronic discovery production is necessary.  Considering that 97% of all business records are kept electronically, you need to understand your client’s IT systems to properly identify, preserve, collect and produce relevant ESI (“electronically stored information”).  In addition, you must understand the opposing party’s IT systems to ask for and receive all relevant ESI you are entitled to.  Cyber Diligence can provide you with the comprehensive technical and legal strategies you need whether you are the requesting or responding party in discovery.   

Pre-Litigation Guidance:

  • Guidance on duty to preserve and “litigation hold” as soon as litigation is reasonably anticipated.
  • Help implement auditable “litigation hold” procedures to avoid pre-collection spoliation (i.e. suspend all document retention policies and procedures and suspend back-up tape rotations) and perform audits to insure “litigation hold” is enforced.

Litigation Support:

  • Understand your client’s IT infrastructure to identify relevant ESI for production. 
  • Assist in overall discovery strategy, including development of language in the document request which identifies relevant ESI with pinpoint accuracy. 
  • Assist in responding party strategy, including identifying and collecting responsive ESI and minimizing privilege review time and expense.
  • Develop a two tier approach to obtain ESI, easily accessible and inaccessible (“burdensome”). 

 Meet and Confer:

  • Query opposing party’s technical staff regarding their IT infrastructure.
  • Assess the validity of technical argument made by the opposing party’s technical staff on availability of ESI.
  • Assist in developing an agreeable identification, preservation, collection, search and production methodology.
  • Provide technical assistance with “not readily accessible ESI” and “cost shifting” issues.

Production Assessment (did I receive everything I asked for?):

  • Determine if opposing party’s discovery production is accurate and complete.
  • Search and sort data efficiently.  Perform gap analysis that may suggest adverse inference.
  • Assist counsel in developing strategic questions to determine if intentional withholding and/or spoliation of ESI have occurred.

We bring a strong balance of forensic technology, investigation, legal, financial accounting and project management expertise to all our eDiscovery consulting assignments.