
any type you may be liable for spoliation
of
evidence and subject to sanctions.
Accordingly, you are hereby on notice
to
preserve all electronic data
as
evidence on any
and all
of
the computers and/or electronic devices described above, including the
following:
a)
Defendants should not initiate any procedures which would alter any active,
deleted, or fragmented files. Such procedures may include, but are not
limited to, storing (saving) newly created files
to
existing drives and
diskettes, loading new software such
as
application programs, rnnning data
compression and disk de-fragmentation (optimization) routines, or the use
of
utility programs
to
pe1manently wipe files, disks or drives.
b)
Defendants should stop any rotation, alteration and/or destruction
of
electronic media that may result
in
the alteration or loss any electronic data.
c) Defendants should not alter and/or erase active, deleted files or file
fragments on any electronic media that may have any relation
to
this matter.
d)
Defendants should not dispose
of
any electronic media storage devices
replaced due to failure and/or upgrade that may contain electronic data
having any relation
to
this matter.
You may comply with this Notice Regarding Non-Destruction
of
Computer Files
by immediately making a copy
of
hard drives on all network servers, computers, and/or
laptop computers. Any and all copies made must include deleted files resident on the
hard drives. Copies
of
hard drives may be made by transferring all information onto an
empty, clean hard drive.
WEG
v.
SPEARS, BT! Page 2
of3
ITs' Notice ofNon-Destrnction
of
Electronic Data