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Sean O’Shea: Tips for Paralegals and Litigation Support Professionals – August 2020

8/1/2020: Maryland Court of Appeals on Social Media Authentication
In Griffin v. State, 419 Md. 343 (2011), the Maryland Court of Appeals found social media evidence must be shown to have not been subject to hacking or other manipulation.

8/2/2020: Relativity Integration Points
Relativity Integration Points (RIPs) assist with the import of data from third party systems into Relativity workspaces.

8/3/2020: Automapping with Relativity Integration Points
Integration points will perform automatic field mapping between a workspace and the load file.

8/4/2020: excel macro to hide multiple ranges of rows
It successfully hid more than 70 ranges in a few seconds.

8/5/2020: NIST Study on Facial Recognition – Too Many False Positives
False positive results were returned far more often than false negatives, and the software exhibited different biases.

8/6/2020: Circuit Court Ruling on PACER Fees
The cost of digital audio equipment used for recordings of trials and other proceedings can be taken into account for PACER fees.

8/7/2020: Emojis and the Law
The Android “Grimacing Face” emoji got the reactions shown in orange on the below chart, but the Apple version of the “Grimacing Face” face emoji got the reactions shown in blue.

Emojis and the Law

8/8/2020: Judges Agree: Limit the Number of Pages in Your Brief
“Let me add an incentive to the production of short and pertinent briefs.  The longer you make your brief, the more likely that most of the pre-argument analysis of your case will be turned over to a law clerk who just finished the bar exam.” – Hon. Arthur L. Alarcon

8/9/2020: D.D.C. Ruling on Adequacy of Search by Navy
“[T]he reasonableness of the Navy’s search is buttressed by the fact that Carlborg has offered ’no suggestion as to where else‘ the Navy ’might have looked for his records or what other search criteria should have been used.’” Carlborg v. Dep’t of the Navy, No. 18-cv-1881 (DLF), 2020 U.S. Dist. LEXIS 142543, at *13 (D.D.C. Aug. 10, 2020) (quoting Peavey v. Holder, 657 F. Supp. 2d 180, 190 (D.D.C. 2009)).

8/10/2020: NIST Guide to Media Sanitization
There are three methods of media sanitization: clear, purge, or destroy.

8/11/2020: Excel OLE action error explained
An OLE action error message may be prompted if you click on a link to a PDF on a worksheet, and then try to OCR it.

8/12/2020: Enforce HTTPS
An admin can force visitors to a Relativity workspace to view it over HTTPS so that requests and responses are encrypted.

8/13/2020: Excel’s TEXT Formula
The formula can easily convert a column of numbers of varying lengths into a standard format with a consistent number of digits.

8/14/2020: Getting a count of volume shadow copies
VSCMount is a tool that helps you check to see if volume shadow copies are available.

8/15/2020: Never Use ‘However’ at the Beginning of a Sentence
Garner instructs brief writers to never use ‘however’ at the beginning of a sentence in order to indicate a contrast, and recommends using ‘but’ instead.

8/16/2020: Mississippi Court of Appeals: Jury Must See Evidence Where Spoliation Unclear
“[T]he  explanation for  the  original record’s  absence  may  be  fully  satisfying  either  that it  was  lost  through  no  fault  of  the  [party],  that  the [party]  deliberately  destroyed  it,  or  as  in  most cases,  somewhere  in  between,  thereby  making  it  a jury  issue.”  Murphy v. William Carey Univ., No  2018-CA-00910-COA, 2020 Miss. App. LEXIS 462, at *28-29 (Miss. Ct. App. Aug. 11, 2020) (quoting DeLaughter  v.  Lawrence  Cty.  Hosp., 601  So.2d  818,  824  (Miss.  1992)).

8/17/2020: 2 GB Text per Document
Relativity will not process more than 2 GB of text for any single document.  Such a document will generate an error that will cause processing to halt.

8/18/2020: Create htm file with links
Use this format:

<div align=”center”>

<a href=”https://www.google.com/”l”>Index2″</a> |

<a href=”https://www.yahoo.com/”l”>Index3″</a> |

<a href=”https://www.mlb.com/mets”l”>Index4″</a> |

<a href=”https://www.edrm.net”l”>Index5″</a>


8/19/2020: Simple File Upload
Relativity’s Simple File Upload tools allows users to load documents into a workspace without using the Relativity Desktop Client.  No more than 100 documents can be loaded at a time.

8/20/2020: Making Relativity Desktop Client Work For You
Don’t miss that you can simultaneously import data into a single workspace using different instances of the Relativity Desktop Client on up to four different computers.

8/21/2020: Common email threading problems
An embedded email link or attachment can cause email threading to be over inclusive.

8/22/2020: Separate email addresses with ; NOT ,
Email addresses in the recipient and cc fields should be separated by semi-colons.  If they are separated with commas, Relativity will read adjacent email addresses as a single address.

8/23/2020: regex from head on and from behind
If you want a regex search to find results from the beginning or end of every line start with (?m)

8/24/2020: District of Maryland Case with a Defendant Known Only By An IP Address
The Court ordered the issuance of a subpoena to produce documents identifying the Doe subscriber.

8/25/2020: ALSPs
The past few years have seen a rise in the number of companies and law firms using ALSPs – Alternative Legal Service Providers -which perform legal research; electronic discovery; and regulatory compliance.

8/26/2020: Excel worksheets that hide themselves
Beware of vba code that automatically re-hides Excel worksheets.  Spreadsheets can be set to make a worksheet you unhid disappear again.

8/27/2020: Regex multiline wildcard
Using (?s) at the beginning of a regex search will let you search from in front and behind while also using a wildcard.

Regex multiline wildcard

8/28/2020: Diffchecker
Diffchecker, is a free online tool that does a fine job of comparing differences between two text or PDF files. Diffchecker can also help you compare multiple versions of an image, allowing you slide back and forth between two versions.

8/29/2020: Florida Court of Appeal rules passcode protected by Fifth Amendment
The Florida Fifth District Court of Appeal agreed with the Petitioner that producing the passcode would require him to disclose the contents of his mind and provide the State with incriminating information that would be used against him. “Distilled to its essence, the revealing of the passcode is a verbal communication of the contents of one’s mind.”. Garcia v. State, No. 5D19-590, 2020 Fla. App. LEXIS 12232, at *8 (Fla. Dist. Ct. App.  Aug. 28,2020)

8/30/2020: finding duplicates with python
You can use a python script to find where there are duplicates in a character set.

8/31/2020: use code to generate list of links on a web page
Right clicking ‘Inspect’ and entering code on the console of the Chrome browser will create a list of all links on a web page.

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Sean O’Shea: Tips for Paralegals and Litigation Support Professionals – July 2020

7/1/2020: Regex to Remove Relativity Numbering on Downloaded PDFs

7/2/2020: UPDATE – How to Automate the Insertion of Hyperlinks in MS Word
This macro can be edited so that the full length of tags with varying numbers of words, symbols and spaces are linked to.

7/3/2020: EOS, EOP, EOG search operators
These operators allow a document database user to run a search that will find where multiple strings appear within a set number of sentences, paragraphs, or pages of one another.   So, for example a search structured this way:

New York W/3/EOP mortgage

. . . will find documents where ‘New York’ appears within three paragraphs of ‘mortgage’.  

7/4/2020: Copy the full file path in Window Explorer
Don’t miss that if you want to copy the full file path for any file that you have selected in Windows Explorer, you can do so by selecting the file and holding down SHIFT.  

7/5/2020: Colorado Change to Comment 8 on Rule 1.1
To maintain the requisite knowledge and skill, a lawyer should keep abreast of changes in the law and its practice, and changes in communications and other relevant technologies, engage in continuing study and education, and comply with all continuing legal education requirements to which the lawyer is subject.

7/6/2020: How good are associates with MS Word?
A survey indicates that most law students don’t know how to perform common tasks in MS Word.

7/7/2020: Get file type counts with PowerShell
get-childitem C:\FooFolder\excels\ -Include *.xls -Recurse

7/8/2020: 2d Cir.: Production Cannot be Compelled Under 28 U.S.C. §1782 for Private International Arbitrations
28 U.S.C. § 1782(a) allows federal courts to compel the production of materials “for use in a proceeding in a foreign or international tribunal”.

7/9/2020: Implementing a Litigation Hold in Office 365
Microsoft 365’s Core eDiscovery tool allows litigation holds to be placed on Outlook mailboxes; SharePoint; OneDrive; and Teams accounts.   You can avoid adding the URL of each OneDrive site, and adding mailboxes one by one, by making use of a PowerShell script.

7/10/2020: Data Stored on Photocopiers
Many Xerox copiers overwrite images automatically by default.  Xerox’s overwriting process conforms to the National Institute of Standard and Technology’s Special Publication 800-88, Guidelines for Media Sanitization. 

7/11/2020: Special Master: TAR May Be Ordered if Production Deficient
“Defendants are cautioned that the Special Master will not look favorably on any future arguments related to the burden of discovery requests, specifically cost and proportionality, when the Defendants have chose to utilize the custodian-and-search term approach despite wide acceptance that TAR is cheaper, more efficient and superior to keyword searching.”  In re Mercedes-Benz Emission Litig., No. 2:16-cv-00881-KM-ESK, at *3 (D.N.J. Jan. 9, 2020)

7/12/2020: python script to replace X number of string occurrences
x = x.replace(“Volume”,”PRODUCTION”,3)

7/13/2020: jEdit
If you are looking for an alternative to the free text editor NotePad++, try jEdit.

7/14/2020: MS Word visual basic code to highlight text not in selected font
When the macro is run it will prompt you to enter the name of the font you do not want highlighted.

7/15/2020: Regex to search for lines which only contain text

7/16/2020: Rapid PDF Count
A field indicates whether or not there are searchable words on every page of a PDF file.

7/17/2020: Getting Around the VLOOKUP 255 character limit
A searched for value of greater than 255 characters gets a result with this custom function, unlike VLOOKUP.

7/18/2020: Forensic Review of Gmail Message to Find What Time It Was Sent
Email messages contain time codes that list the number of 100 nanosecond intervals since the start of Windows epoch time – January 1, 1601.

7/19/2020: Reviewing documents with conceptual indexes in Relativity
Conceptual indexes can be used for clustering, categorization, finding similar documents, keyword expansion, and concept searching.

7/20/2020: No Permission for Analytics Index Without Search Index Permissions
Keep in mind that in order for view / edit / add / delete permissions to an analytics index in a Relativity workspace to be effective, having those permissions alone is not enough.   A user must also have permissions for the search index in order to use analytics index permissions.

7/21/2020: vba code to run a macro on multiple Word Files
The code must to edited to list a folder with source files.

7/22/2020: Schrems II – US Data Protection Inadequate Under the GDPR
The Court of Justice of the European Union held that, “the limitations on the protection of personal data arising from the domestic law of the United States on the access and use by US public authorities . . . are not circumscribed in a way that satisfies requirements that are essentially equivalent to those required under EU law, by the principle of proportionality, in so far as the surveillance programmes based on those provisions are not limited to what is strictly necessary.”

7/23/2020: History of the Congressional Record
Between 1837 and 1873 the debates and proceedings of Congress were published in the Congressional Globe.

7/24/2020: XCOPY to copy and rename files
With the XCOPY command the /Y switch will overwrite any existing files.  

7/25/2020: S.D. Ohio: Lawyers Must Understand Cloud Computing
The Defendants were sanctioned for failing to identify and preserve data saved with salesforce.com.

7/26/2020: Garner’s Guide to Making Briefs More Persuasive: Authority Split on How to Handle Your Numbers
When editing a brief you should confirm that the numbers one to ten are spelled out, and numerals are used for all higher numbers.

7/27/2020: Microsoft Finds Working From Home Makes Employees Busier
A key finding is that people have actually been working four more hours per week than before pandemic. 

7/28/2020: Sorting and Filtering Can Break Links
Although the blue, underlined text appears in the cell, nothing happens when you click the link.

7/29/2020: Preservation Subpoenas
A mere written demand to preserve ESI does not create a binding legal duty on a third party to not destroy the data.

7/30/2020: Relativity’s Not So Locked Lockbox?
Relativity includes a customer lockbox feature which prevents its support and operations teams from viewing customer data. 

7/31/2020: Edit Videos in PowerPoint
A video will not be saved at its new length, until the presentation is compressed.

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Sean O’Shea: Tips for Paralegals and Litigation Support Professionals – June 2020

6/1/2020: When to use – ; – ; or —
A hyphen – to separate words.

An en dash – to separate ranges.

An em dash — in place of a colon, comma, or parentheses.

6/2/2020: DFIR – Digital Forensics and Incident Response
Digital Forensics and Incident Response (DFIR) is a term for the application of digital forensic techniques to cyber security.

6/3/2020: The Amcache registry and how to access it
Amcache is a registry hive on Windows operating systems which has information on applications that have been run on a PC.

6/4/2020: Parsing prefetch files
Prefetch files stored at C:\Windows\Prefetch can be analyzed to show which programs have been run on a Windows computer.

6/5/2020: Regex search for Month, DD, YYYY

6/6/2020: Input Method Editor
The Windows Input Method Editor will let you switch to almost any foreign language by clicking an icon in the system tray.

Input Method Editor

6/7/2020: New York Appellate Division E-filing Guidelines
The guidelines specifically state that, “PDFs that contain skeletal bookmarks (i.e. missing headings), minimal Table of Contents or no bookmarks will be returned for correction.”

6/8/2020: The 90 Second Test
A good brief should open by addressing the deeper issues at hand, and in 90 seconds make clear its primary point.  Premises making reference to facts should be quickly stated, and then a yes or no question should be asked so that only one answer to it appears to be possible.  Draw a conclusion after reviewing the issues in 75 words or less.

 6/9/2020: Security Orchestration, Automation and Response (SOAR)
Security Orchestration, Automation and Response (SOAR) refers to the use of automated workflows to facilitate responses to security incidents.

6/10/2020: Dealing with large Relativity workspaces on SQL Server
A SQL Server table for a Relativity workspace will take up approximately 50 GB of disk space for a million documents.  The SQL Server has RAM limits – the 2016 edition is limited to 128 GB of RAM.

6/11/2020: HDDs and SSDs
A SSD device does not include any moving parts.  It differs from a hard disk drive (HDD) which stores information on spinning disks.

         HDD                      SSD


6/12/2020: Crypto Sheriff
Crypto Sheriff is an online service which can help decrypt files that have fallen victim to a ransomware attack.   See: https://www.nomoreransom.org.   The “No More Ransom” project helps identify keys needed for decryption.  It is a joint project of Europol, Kaspersky, McAfee, and the national police of the Netherlands.

6/13/2020: E.D. Cal.: Employees Taking Trade Secrets Must Cover Forensic Analysis of Their Electronic Devices
“Given that defendants have conceded improperly taking ExamWorks’ trade secrets and the court has found they did so intentionally, they have not overcome the presumption that as the responding party they must bear the expense of discovery, including the costs of the forensic expert.” ExamWorks v. Baldini, No. 2:20-CV-00920-KJM-DB, 2020 U.S. Dist. LEXIS 103366, at *44 (E.D. Cal. June 11, 2020)

6/14/2020: Nuix Workstation
In order to process Lotus Notes archives and OCR documents with Nuix Workstation you need to install additional software.

6/15/2020: Craig Ball on Forms of Production
For email, ask, “Can the form produced be imported into common e-mail client or server applications?”

6/16/2020: Excel TEXT Function to Display Date in Formula
=”Letter dated, “&TEXT(A2,”mm/dd/yyyy”)

6/17/2020: Semi-structured data
Semi-structured data is data that is not organized in a relational database, but which contains tags that separate elements of the data.   An object database uses semi-structured data.

6/18/2020: Garner’s Guide to Making Briefs More Persuasive: Tip 12 – Avoid one sentence issue statements
When writing an issue statement, don’t try to do it with one sentence, and certainly don’t begin with ‘Whether’ or another interrogative word.  An issue statement should follow a chronological order, and end with a pointed question.

6/19/2020: D.D.C.: Notice to Court of E-Discovery Search Problems Excuses 8 Day Delay in ESI Request Response
“Defendant also represented that it had modified the emails to provide Bates numbering. Thus, Defendant’s production of the emails did not ‘replicate[] the manner in which they were originally kept’ and Defendant was required to ‘label them to correspond to the categories in the request[.]’ Fed. R. Civ. P. 34(b)(2)(E)(i).  Defendant shall supplement its electronic discovery responses to comply with this requirement.”  Ronaldson v. Nat’l Ass’n of Home Builders, No. 19-01034, 2020 U.S. Dist. LEXIS 107436, at *27 (D.D.C. June 3, 2020).

6/20/2020: using Python in Windows
After you have installed Python on a Windows operating system, you can start the Python interpreter by entering Windows command prompt and entering the command ‘py’

6/21/2020: PATH System Variable
Windows 10 uses a PATH system variable to track the paths for programs that can been then be referenced in command prompt.  It can be set in System Properties on the advanced tab.

6/22/2020: Windows Recycle Bin $I and $R files
Inside a Recycle Bin you may find files which begin with either ‘$I’ or ‘$R’.  A file beginning with ‘$I’ will contain data about a file that has been deleted.  A file beginning with $R will contain the actual content of a file.

6/23/2020: Elasticsearch
Elasticsearch is an open source NoSQL database that Relativity Data Grid uses with the Audit application, which runs reports on user activity.

6/24/2020: Extracting Links for Multiple Documents in a Box Folder
You can get multiple links for documents in a folder on Box by reviewing the page source code.

6/25/2020: eDiscovery with Microsoft Teams
Teams chat messages are journaled with users’ Outlook mailboxes, so a shadow copy of these messages is included when one is prepared of email messages and other Outlook data.

6/26/2020: Macro to merge Word files
This macro will prompt you to select the folder with your source files.

6/27/2020: New York Court Rules Mandate E-Discovery Competency
The rules state that, “. . . counsel for all parties who appear at the preliminary conference must be sufficiently versed in matters relating to their clients’ technological systems to discuss competently all issues relating to electronic discovery.”

6/28/2020: Some States Qualify Duty of Technology Competency
New York’s professional rules modify comment 8 to Rule 1.1, to emphasize that attorneys have a duty to keep ESI secure.

6/29/2020: Excel formula to extract folder from file path
This method can be adjusted to pull any one of multiple folders in a file path.

6/30/2020: Sedona Guide for Judges
The month, the Sedona Conference released the third edition of The Sedona Conference Cooperation Proclamation: Resources for the Judiciary, Third Edition.  This guide makes seven principal recommendations for judges on how to handle electronic discovery in civil actions.

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Sean O’Shea: Tips for Paralegals and Litigation Support Professionals – May 2020

5/1/2020: (California Styling)
The California style is distinguished by enclosing citations in parentheses and putting the venue and year between the case name and reporter cite.

5/2/2020: Predicting the number of top level clusters
The general rule that a higher generality setting will lead to fewer top-level clusters in Relativity will not always turn out to be true.

5/3/2020: Companies are sharing your data with Facebook
What is Off-Facebook activity?  By default, your Facebook account permits businesses to share information concerning your online activity with Facebook.

5/4/2020: Pivot Table Cache Limit
Excel creates a cache of a pivot table’s outside data source (which shows the totals listed in the table itself based on the original complete data source) but only retains the first 65,536 rows of the data source.

5/5/2020: Excel formula to pull column headings when given value is entered
A formula in Excel to extract the column headings in a range of data for which a given value is entered.

Excel formula to pull column headings when given value is entered

5/6/2020: PowerShell Script to Get Hash Values of Multiple Files in Multiple Folders
PS C:\Users\SeanKOShea> Get-FileHash -Algorithm MD5 -Path (Get-ChildItem “C:\FooFolder\baseball2\*.*” -Recurse -force) | export-csv c:\FooFolder\Batch01b.csv

5/7/2020: certutil command to generate hash values for multiple files
You can use this script to generate a list of hash values for multiple files in a single folder: for %F in (*) do @certutil -hashfile “%F” MD5 | find /v “hashfile command completed successfully” >>list.txt

5/8/2020: INDEX MATCH divided is faster than Excel
A nested INDEX MATCH formula only runs slightly faster than VLOOKUP, but when the INDEX and MATCH formulas are placed in separate cells, results can be obtained almost five times faster than with than with VLOOKUP.

5/9/2020: Speeding up VLOOKUP
To run a binary search but avoid an approximate match, use a VLOOKUP inside a IF . . . THEN formula


5/10/2020: Renaming Tables and Queries in Access Can Crash Your Database
If you select the option to ‘Track name AutoCorrect info’, and ‘Perform name AutoCorrect’ under File . . . .Options . . . Current Database, Access can avoid errors by updating object names automatically.

5/11/2020: Relativity Integration Points
Relativity Data Transfer uses integration points to transfer saved searches; folders; and production from a Relativity workspace to another workspace or a load file.  Integration Points also substitute for Relativity Desktop Client in importing load files or Office 365 directories into a workspace.

5/12/2020: N.D. Cal. 26(f) ESI Checklist
The United States District Court for the Northern District of California has posted a checklist on its site, for parties to consult when addressing ESI issues at Rule 26(f) meet and confer.

5/13/2020: Draft Declarations – 28 U.S.C. § 1746
When filing a declaration in federal court, reference 28 U.S.C. § 1746 which provides that a matter may be supported by an unsworn declaration as being true under the penalty of perjury.

5/14/2020: Excel formula to parse out Nth words in cell
The number of the string to be extracted is referenced in cell $B1

=TRIM(MID(SUBSTITUTE($A2,” “,REPT(” “,LEN($A2))), (B$1-1)*LEN($A2)+1, LEN($A2)))

Cell $A2 references the cell with multiple strings that is to be reviewed.   The formula uses the LEN formula to calculate the position of the string, and the MID formula to extract the string.

5/15/2020: Running Regex searches in an Access database
Visual Basic code creates a RegEx function that you can use in SQL query.

5/16/2020: Garner’s Guide to Making Briefs More Persuasive: Tip 9 – Allow time for a full citation check of both the record and the caselaw
It will take a full day to check the fact and legal citations in a brief.

5/17/2020: Calculated Items in Pivot Tables
When you’ve created a pivot table in Excel, you can easily add two fields together and list the result in new field – one not present in your original data source.

5/18/2020: DAT-daddy to parse by ¶ and þ in Excel
ENF Discovery has a great add-in for Excel that can help you parse out fields in Concordance .dat load files.

5/19/2020: PowerShell script to merge .csv files
A PowerShell script posted on the Microsoft Scripting blog here, can be used to merge multiple .csv files together.

5/20/2020: vba code to unprotect Excel worksheet
I tested this macro tonight on a workbook protected with Excel 2019 using a four-digit number, a dictionary word, a short phrase, and an eight character alphanumeric code and it cracked each one in seconds.

5/21/2020: Finding Hidden Dialog Boxes with WinLister
If you’re having trouble finding a hidden dialog box that’s preventing you from accessing an application, try downloading another great utility from Nirsoft: WinLister.

5/22/2020: Cornell Survey of Juror Thoughts on Trial Technology
“Many jurors are accustomed to learning through technology, and technologically enhanced presentations present an ideal platform to summarize and connect the dots between the evidence presented at trial and the applicable law in a way that is especially useful for visual learners.”

5/23/2020: D. Colo. Applies Alice Test for Hierarchical Data Storage System
The Supreme Court Alice test was applied for a patent on a hierarchical data storage system used for security and surveillance.

5/24/2020: The CSI Effect
Dramas which focus on forensic investigation in criminal cases have led to there being a large number of people in jury pools who expect to presented with extensive forensic evidence.  This in turn raises the standard of proof for public prosecutors.  Circumstantial evidence may not be given as much importance as it should.

5/25/2020: In-Depth Study on the CSI Effect
The study reached the conclusion that, “participants who demonstrated a higher level of pro-prosecution forensic evidence bias perceived weak DNA evidence to be of higher probative value in this murder trial scenario.”

5/26/2020: Unicode compliance
MS Exchange uses unicode for PST archives.  However individual email messages saved with a .msg extension don’t use unicode for the email header fields.  Tools which collect local .msg files may garble the text of email headers unless an adjustment is made for the Outlook encoding.

5/27/2020: Windows’ Character Map
Don’t miss that Windows includes an application called Character Map which you can use to look up the alt codes and unicodes of thousands of different characters.

5/28/2020: DATEVALUE to force Excel entries into the Date format
Don’t miss that you can use the DATEVALUE function in Excel to correctly format dates entered in a column, if selecting the cells and right clicking and selecting Format Cells and picking the date format on the Number tab doesn’t do the trick.

5/29/2020: Excel formula to go from A to ZZ

5/30/2020: Garner’s Guide to Making Briefs More Persuasive: Tip 10 – Revise. Then proof carefully
Make several passes: once for punctuation; once for formatting; once for transitions; once to confirm the headings are consistent.

5/31/2020: Editing marks
Many common editing marks used in proofreading can be entered with Unicode references. 2050 gives you the close up space mark: ⁐

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Sean O’Shea: Tips for Paralegals and Litigation Support Professionals – April 2020

4/1/2020: Relativity and JVM RAM
You can improve the performance of Relativity analytics operations by increasing the amount of RAM available for Java.  The Java heap is the amount of memory allocated to the Java Virtual Machine (JVM).

4/2/2020: 32-bit Operating System RAM Limit
Note that if you have a 32-bit operating system, you will be limited to using 4 GB of RAM – and in practice something closer to 3.5 GB of RAM.

4/3/2020: VBA code to unprotect multiple workbooks with the same password
This Excel macro can also change a password to something else.

4/4/2020: S.D. Ala.: PACER Fees Cannot Be Taxed Because Parties Get a Free ‘First Look’
The Southern District of Alabama held that PACER charges should not be taxed because the parties receive a free look at court filings.

4/5/2020: Garner’s Guide to Making Briefs More Persuasive: Tip 4 – Start Your Brief With a Nonlinear Outline
Garner recommends the use of a nonlinear outline – you are not always finished with one concept, before you move onto the next concept.  Use an outline in the form of a whirlybird.

4/6/2020: Highlighting Cells in a Range with Data Different from the Top Row
On the Home tab, go to Find & Select . . .Go to Special to access a column (or row) differences tool.

4/7/2020: Update Windows Group Policy
Gain access to network directories and rights to applications with the command: gpupdate /force

4/8/2020: The Sedona Conference on Questions to Ask Law Firms About Data Security
Law firms should use WFA2 for public wifi.

4/9/2020: E.D. Cal.: Throwing Out Figures for Cost of Data Decryption Conclusory
“]A]lthough Defendant repeatedly throws out figures exceeding three million dollars to create the appearance that the review process will be costly, it is unable to provide any supportable estimate of the number of files that will need to be reviewed or the cost of reviewing a file–which comprise the bases for the exorbitant cost estimate.”

4/10/2020: New York State Notary Public Database
You can confirm a notary’s license is current by searching for their name in this database.

4/11/2020: vba code to count rows in multiple .csv files
It will generate a list of the source files in one column and the total number of rows in each in a second column.

4/12/2020: Garner’s Guide to Making Briefs More Persuasive: Tip 5 – At an early stage, frame your issue statements and point headings
The opening paragraph of a brief should make clear which side the author is on, and clearly state the problem.  Concentrate on the legal issues and how their resolution will affect people.

4/13/2020: All network cables are not the same
Get a CAT 5e or CAT 6 ethernet cable to support speeds of up to 1 Gbps.

4/14/2020:  Use VLOOKUP to find multiple values in an array
If you want to find multiple values in the array for the successive times that the searched for value appears, you can do so with the help of Excel’s COUNTIF formula.

Use VLOOKUP to find multiple values in an array

4/15/2020: Garner’s Guide to Making Briefs More Persuasive: Tip 6 – Arrange your points from most to least important
Make sure that your brief has a recognizable form – don’t let it begin or end out of nowhere.   The points in a brief should be placed in descending importance in order to increase the chance that the most important points will be read carefully.

4/16/2020: Use Del. C. for statutes when filing in Delaware
The Superior Court of Delaware’s citation guide specifies that this italicized format be used:  14. Del. C. § 101

4/17/2020: dtSearch in Relativity to exclude docs including your search term
Simply follow the search term with:  NOT w/0

. . . and then enter the phrase or phrases you don’t want to appear in the search results.

4/18/2020: Searching for symbols in Relativity
In the Alphabet section of the dtSearch index, below where is says “[Letters] // Original letter, lower case, upper case, unaccented” enter the symbol you want to search for four times preceded by a space each time.

4/19/2020: PowerShell script to count words, lines, and characters in multiple PDF files
The script is a good way to detect near duplicate PDF files

PowerShell script to count words, lines, and characters in multiple PDF files

4/20/2020: Searching for symbols in Relativity continued . . .
Characters outside the ASCII code range such as § and £ must be listed by their Unicode value in a dtSearch index or they will not be searchable.

4/21/2020: batch file to get line counts for multiple .csv and .txt files
Put the file in the same folder containing the source files.

4/22/2020: Garner’s Guide to Making Briefs More Persuasive: Tip 7 – Begin and End the Arguments with Points in Your Favor
Swiftly undercut the opposing party’s positions – don’t explain them at great length.

4/23/2020: page counts per GB
Catalyst has much lower counts than other ediscovery service providers.

4/24/2020: windows command to extract data from specific columns in a .csv file
This will work only up to the 31st column in a .csv file.

4/25/2020: Garner’s Guide to Making Briefs More Persuasive: Tip 8 – Write a draft straight through without stopping to edit
Garner recommends writing down a draft un-selfconsciously to the end, and only considering revisions afterwards.

4/26/2020: HHS on the Cloud and HIPAA
HIPAA does not require CSPs to allow customers to audit their security practices.

4/27/2020: powershell script to extract specific columns from a .csv file
This will allow you to extract data beyond the 31st column in a .csv file.

4/28/2020: Court Stats
Get interactive tables on state court data at http://www.courtstatistics.org/

4/29/2020: Excel formula to pull data up to the first delimiter

Excel formula to pull data up to the first delimiter

4/30/2020: Excel formula to pull data between two delimiters in cell with multiple delimiters

Enter the relative position of the delimiter in front of the value you want to pull at the end of the first SUBSTITUTE formula; the delimiter which comes after this value at the end of the second SUBSTITUTE formula, and then enter the position of the delimiter in front at the end of the third SUBSTITUTE formula.

Justice and Law concept image

Sean O’Shea: Tips for Paralegals and Litigation Support Professionals – March 2020

3/1/2020: Quarter Inch Cartridges
Quarter Inch Cartridges can range in size from 20 MB to 40 GB.  Mini-QICs, QIC-40s and QIC-80s can be accessed with a standard floppy drive.

3/2/2020: Powershell script to find unique values
Use the compare-object command in PowerShell to find the unique values two sets.

3/3/2020: Ransomware Attack on Epiq
It may have resulted from the continued use of Windows 7.

3/4/2020: Relativity Collect
Relativity Collect is an application for RelativityOne, which can assist with the collection of email and documents from Office 365.

3/5/2020: D.N.M.: Preservation Order Requires Extreme Caution In iPhone Data Transfers
The Plaintiff’s failure to understand the nature of data transfer was no excuse.  “]T]his ignorance was all the more reason to exercise extreme caution in doing anything that might alter the information stored on the phone.”

3/6/2020: Ablate
The term ablate is used to describe the process of storing data on in unalterable form on an optical disc.

Ablate graphic

3/7/2020: Differential Back-ups
Differential back-ups are a copying process that only involves new or modified data.

3/8/2020: Hierarchical Storage Management (HSM)
Hierarchical Storage Management (HSM) is the auto copying of online files to local storage.

3/9/2020: Image Keys
Image Key is a term used to refer to the name of an image and cross reference to the image’s file in a document load file.

3/10/2020: Lempel-Ziv & Welch
Lempel-Ziv & Welch is a compression method used for TIFF images.

3/11/2020: Kofax Board
A Kofax Board is an interface with document scanner that improves image quality.

3/12/2020: OPT File
OPT file, a file to link Bates Number to path of an image file.

3/13/2020: T3 Connection
A T3 connection is an internet connection running at 44 MB per second.

3/14/2020: Beware of Zombie Cookies
Zombie cookies are cookies outside a browser’s  normal cookie storage location that get recreated after deletion.

3/15/2020: CIA Triad
Note that when you see a reference to the CIA Triad, it’s a reference to the cybersecurity framework and refers to confidentiality, integrity, and availability.

3/16/2020:Verbatim Coding
Verbatim coding is  a term used to refer to manually copying information from documents onto an index, providing an analysis of unstructured data.

3/17/2020: Judgmental Sampling
The term judgmental sampling is used to refer to creation of a subset of documents based on person’s (perhaps a subject matter expert), familiarity with the document set.   It involves a degree of bias in contrast to random sampling.

3/18/2020: Super DLT
A Super DLT is a kind of a magnetic back-up tape.  Super DLT cartridges usually can hold either 110 GB or 300 GB and require a specialized drive to access the data.

3/19/2020: Keep your hotel keycard away from your smartphone
Doing can cause the magnetic stripes on the card to lose their encoding.

3/20/2020: Asymmetrical Encryption
This technique allows anyone to confirm the existence of a Blockchain transaction, but the content of the transaction can only be accessed by the participating parties.

3/21/2020: Bar Chart Races
Flourish online data visualization site lets you easily create bar chart races.

3/22/2020: Garner’s Guide to Making Briefs More Persuasive: Tip 1 – Know Thy Reader
Distill your message on the first page.

3/23/2020: Why email isn’t secure
Microsoft’s documentation for Exchange notes that “This default configuration allows Exchange to provide opportunistic TLS on all inbound and outbound SMTP connections. Exchange attempts to encrypt the SMTP session with an external messaging server, but if the external server doesn’t support TLS encryption, the session is unencrypted.”

3/24/2020: Excel’s EXACT Function
VLOOKUP is not case sensitive, but you can nest EXACT in a LOOKUP formula to do a case sensitive search.

3/25/2020: Make Excel Work Harder by Increasing the Thread Count
In order to confirm that you’re getting as much juice out of Excel as your computer can give, increase the thread settings.  Go to File . . . Options . . . Advanced . . . and scroll down to the Formulas section.

Make Excel Work Harder by Increasing the Thread Count

3/26/2020: Sorting Rows in Excel
A macro to sort data on an Excel worksheet by rows instead of columns.

3/27/2020: D.C. Circuit Bill of Costs Ruling: Hosting and Processing Not Covered by § 1920
1920 only “authorizes taxation of costs for the digital equivalent of a law-firm associate photocopying documents to be produced to opposing counsel.”

3/28/2020: Garner’s Guide to Making Briefs More Persuasive: Tip 2 – Plan every writing project by breaking it up – and carry it out in stages.
Use the Flowers Paradigm – Madman, Architect, Carpenter, Judge – when preparing a brief.

3/29/2020: Garner’s Guide to Making Briefs More Persuasive: Tip 3 – When first working on a writing project, let your madman run loose
Take copious notes while trying to come up with imaginative approaches for conveying your argument.

3/30/2020: Azure vs. COVID-19
Demand for Azure cloud services has increased by 775% in areas effected by orders requiring social distancing.

3/31/2020: Zoom Bombing
Use the waiting room feature to control who can enter your zoom meeting.

Justice and Law concept image

Sean O’Shea: Tips for Paralegals and Litigation Support Professionals – February 2020

2/1/2020: Illinois Supreme Court: Biometric Information Privacy Act Protects Rights Even If No Injury
Illinois Supreme Court rules that Biometric Information Privacy Act does not require actual injury when fingerprint collected without notice or consent.

2/2/2020: Relativity Pricing
Since 2019, Relativity has only charged 33% as much for data stored for early case assessment as it charges for active data, and only charges users that work in RelativityOne (its SaaS software as service) 60% of regular user rates.

2/3/2020: Relativity Pay As You Go Pricing a New User Interface
Aero UI will allow for faster load times.

Relativity Pay As You Go Pricing a New User Interface

2/4/2020: Kubernetes
Kubernetes (K8s) is a system that automatically deploys applications to different web connected computers or hosts.

2/5/2020: Relativity and FedRAMP Certification
Relativity announced this month that it expects to achieve the FedRAMP cloud security authorization later this year.

2/6/2020: findstr command to filter out files with given extension
dir | findstr /v “.pdf”

2/7/2020: NIST Study on Collection of Cell Phone Data
The study showed that Cellebrite Physical Analyzer could not collect stand-alone files and GPS related data on the HTC One Mini.

2/8/2020: NIST Study on Collection of Cell Phone Data – Paraben Electronic Evidence Examiner
NIST/DHS study on collection of data from Android phones using a Paraben tool shows when certain types of data are missed.

2/9/2020: JTAG, Chip Off, and ISP Extractions of Data from Mobile Phones
JTAG data extraction: soldering wires to ports; ISP data extraction: soldering wires to board; Chip Off: the memory card is removed and inserted in a specialized reader.

2/10/2020: Bloomberg’s Brief Analyzer
You can download cases cited in a brief faster than with the Lexis Get & Print tool.

2/11/2020: Exchange Litigation Hold Can Max Out Recoverable Items Folder
The default max size is 30 GB.

2/12/2020: SEC Letter: Produced Exchange Order Audit Trail Info Not Covered By Regulation SCI
Regulation Systems Compliance and Integrity covers all national securities exchanges and requires that their trading systems have adequate security, capacity, and integrity.

2/13/2020: Zero Trust
Zero Trust refers to an approach to cyber security that operates on the premise that an organization should never trust any outside user, device, network, or application.

2/14/2020: RBAC
RBAC stands for role based access control.  This is a security protocol which is commonly used in large organizations.  The key concept is that permission to perform operations and access to objects are assigned to specific roles, rather than individuals.

2/15/2020: Nevada Court of Appeals: No Plain Error in Admission of Facebook Profile Exhibits Without Showing Acquisition with Factual Specificity
Nevada Court of Appeals rejects abuse of discretion claims in admission of Facebook, Text Message, and Phone Tracking App ESI.

2/16/2020: Clearing iPhone RAM
iPhone RAM can be cleared by going to Settings . . . General . . . Shut Down and holding the home button for 5 seconds.

2/17/2020: E.D. Tex.: Cloned Discovery from Another Case Is Improper
Cloned discovery is only permitted when the fact of the production of the documents in another case is relevant to the present case.

2/18/2020: Excel DATEDIF formula to show time gap between two dates
show day, month, or year gap between two dates in





2/19/2020: Excel formula to check how much two cells match




ROW(INDIRECT(“A1:A” &C2)))))

2/20/2020: Edit Video Clips in Windows 10
Don’t miss that you can easily edit video files in Windows 10.

Right click on a video file in Windows Explorer and select Open with . . . Photos

2/21/2020: Avoid Zero Result with ISBLANK
In Excel use the ISBLANK formula to avoid a 0 result.

2/22/2020: App to communicate securely with witness
A judge ruled the WitComapp does not comply with New York state law.

WitComapp image

2/23/2020: PowerShell Command to Create a Zip File
Compress-Archive -Path F:\MyData -DestinationPath F:\foofolder

2/24/2020: Get List of Restore Points
PowerShell Command Get-ComputerRestorePoint

PowerShell Command Get-ComputerRestorePoint

2/25/2020: SQL Fiddle
You can use the free online tool SQL Fiddle to practice your SQL scripting.  See: http://sqlfiddle.com/

2/26/2020: New Jersey Appellate Court Denies Motion to Suppress Warrantless Disabling of Cell Phone Lock
The New Jersey Superior Court Appellate Division held that putting a cell phone in airplane mode and disabling the lock on the phone was unlawful.  However, citing the decision of the Supreme Court of United States in Riley v. California, 573 U.S. 373 (2014), the Court found that there was no Fourth Amendment violation because no data was taken from the phone.

2/27/2020: Auto animate bullets individually
In PowerPoint you don’t have to animate each bullet point one by one.

Image of Auto animate bullets individually

2/28/2020: Full Duplex
Full Duplex is a term used to refer to data transmission that operates at the same speed between two devices in both directions simultaneously.

2/29/2020: The Official Regex Search for Email Addresses
There is an official regex to search for any email addresses permitted under the RFC 5322 protocol.

Justice and Law concept image

Sean O’Shea: Tips for Paralegals and Litigation Support Professionals – January 2020

1/1/2020: Conceptually Rich Documents for Conceptual Indices in Relativity Analytics
When setting up a training set to be used for the creation of a conceptual index in Relativity, be sure to exclude computer generated files.   Include conceptually rich documents in the set.  Excel spreadsheets will rarely be examples of conceptually rich documents.  Databases should also be avoided.

1/2/2020: Special Master: Confidentiality Order Balances EU GDPR
“Special Master believes the Discovery Confidentiality Order provision allowing a producing party to designate and protect as ‘Highly Confidential’ information that the producing party claims to be Foreign Private Data—such as employee names, sufficiently balances the EU’s interest in protecting its citizens private data and the U.S. legal system’s interest in preserving and maintaining the integrity of the broad discovery provisions set forth in the Federal Rules of Civil Procedure.” In re Mercedes-Benz Emissions Litig., No. 2:16-cv-881 (SDW) (JAD), 2019 U.S. Dist. LEXIS 223132, at *15 (D.N.J. Nov. 4, 2019)

1/3/2020: Disabling Formula Updates for Broken Links in Excel
If you already have a different Excel file open, with the default ‘Automatic’ setting activated, a setting of a new file to only manually update formulas will be overridden and formulas will automatically update.

1/4/2020: Opened Emails Not Protected by the SCA
“It thus appears that most courts have held (and I agree) that the SCA doesn’t reach and protect undeleted emails that have already been delivered and opened by the intended recipient.”  Sartori v. Schrodt, No. 3:18cv204-RV/HTC, 2019 U.S. Dist. LEXIS 223533, at *29 (N.D. Fla. Nov. 25, 2019)

1/5/2020: Court Orders Co-owned Businesses Dissolved Because of Dispute of Over Paying for Imaging of Servers
“The bickering over who shall pay the $1,500 cost to image the server evidences the dissention, deadlock and division.  Their inability to cooperate to the detriment of their co-owned companies yields one conclusion: dissolve all of the joint businesses, now.” Besen v. Doshi, Index No. 652691/2018, 2019 N.Y. Misc. LEXIS 6835, at *12 (N.Y. Sup. Ct. Dec. 27, 2019).

1/6/2020: Sedona Commentary on Non-Party Discovery
A wider range of expenses are permitted for non-party discovery than for regular discovery.   “Courts may allow non-party expenses to include printing costs and technology consulting fees as well as costs associated with collection, database creation, and, under certain circumstances, document review and privilege log preparation.”

1/7/2020: Javascript to remove blank pages from PDFs.
This script will remove any pages which don’t’ contain searchable text.

1/8/2020: Find rows with duplicate data with conditional formatting in Excel
This method uses the CONCATENATE formula.

1/9/2020: VBA code to merge cells with consecutive duplicate entries in Excel
Macro which you can use to merge consecutive cells with duplicate entries in a column in an Excel.

1/10/2020: Find and Replace Multiple Strings in Excel
VBA code will replace strings listed in two columns on Sheet1 on all other worksheets.

1/11/2020: D. Nev. Issues Protective Order for IMEI Data
The Court also agreed to the Plaintiff’s request for a protective order for a spreadsheet with an IMEI analysis of the Defendants’ phone data.   IMEI stands for “International Mobile Equipment Identity”. It is used to identity mobile phones.  The IMEI number identifies the phone, but not the actual subscriber.

1/12/2020: International Mobile Equipment Identity
You can get the unique IMEI id number for your mobile phone by dialing *#060.

1/13/2020: Splitting Delimited Text Inside Cells Onto New Rows
VBA to split text separated by delimiters inside a cell onto new rows, with data to the right copied on the new rows.

Splitting Delimited Text Inside Cells Onto New Rows

Splitting Delimited Text Inside Cells Onto New Rows

1/14/2020: The SHA-1 hash function is more vulnerable than ever before
A paper shows how PGP encryption keys can be created with different IDs but the same SHA-1 hash values.

1/15/2020: The different types of data extraction
In advanced physical extraction forensics tools can be used to recover flash memory.   This involves recovering data from memory chips, which must be removed from a device.

1/16/2020: Medical Social Media
70% of American physicians have a Doximity profile.

1/17/2020: Excel vba code to use a RegEx search to make part of text inside a cell boldfaced
Vba code you can use to run a regular expression search on a column in Excel to boldface some but not all of the text inside a cell.

1/18/2020: S.D. Ind.: Searching Electronic Records Cannot Be Taxed Under 28 U.S.C. § 1920
“Fees for searching electronic records and for research aren’t recoverable under § 1920, but must be sought in a motion for attorneys fees.” In re Method of Processing Etha Related Subsystems ‘858 Patent Litig., No. 1:10-ml-02181-RLM-DML, 2020 U.S. Dist. LEXIS 8694, at *14 (S.D. Ind. Jan. 15, 2020)

1/19/2020: REPLACE formula
Don’t miss how helpful Excel’s REPLACE formula can be.  You can use it to replace X number of characters starting at a given position in a cell.

1/20/2020: Replace alt codes in MS Word
You can find and replace any character in a Word document by preceding its alt code with a ^

1/20/2020: Replace alt codes in MS Word

1/21/2020: CVE-2020-0601 Vulnerability Lets Windows Install Malware
Windows uses a document link library, Crypt32.dll, to keep track of trusted certificate authorities.  There’s a flaw in the .dll (which Microsoft recently posted a patch for) which allows it to incorrectly approve malicious software and web sites.  The vulnerability is named CVE-2020-0601.

1/22/2020: CTRL + D without formatting
VBA code that can be used to autofill a selected range of cells with the data in the cell above the range, but without copying the formatting from the source cell, as would be done if the common CTRL + D command were used.

1/23/2020: S.D.N.Y.: CAL Software Name and Workflow Makes Discovery Transparent
“In this case, defendants have represented that they have provided detailed information regarding the collection criteria they used, the name of their continuous active learning (“CAL”) software, their CAL review workflow, and how they intend to validate the review results. That is sufficient information to make the production transparent.”  Kaye v. New York City Health & Hosps. Corp., 18-CV-12137 (JPO) (JLC), 2020 U.S. Dist. LEXIS 9240, at *4 (S.D.N.Y. Jan. 21, 2020),

1/24/2020: How ephemeral is Snapchat?
When two users communicate in a one on one chat. their messages will be deleted when the chat ends, but the settings can be changed so these messages are retained for 24 hours.

1/25/2020: In-Place eDiscovery in Microsoft Exchange
A single mailbox can have multiple in-place holds, but no more than 500 search terms can be used.

1/26/2020: Emails Purged From Outlook May Still Exist
After an email in Outlook is purged from the Recovered Items folder, it may not disappear until the Managed Folder Assistant processes the Purges folder – the default work cycle is 1 day.

1/27/2020: Removing Line Breaks in Excel
The CLEAN formula takes out characters that cannot be printed.  It will remove other line breaks that the CHAR(10) and CHAR(13) don’t catch.

1/28/2020: Excel formula to extract formula path

1/29/2020: Model Rule 3.3 and Electronic Discovery
Obligation under Rule 3.3 to show candor to the tribunal may override an attorney’s duty to protect the confidentiality of a client’s data.

1/30/2020: Excel formula to find row number hit appears on
You can use the Excel MATCH formula to find the row number of that a value in a range appears in.


The MATCH formula searches for where the value in cell F2 appears in column A and then the ROW formula returns the row number that value appears on.

1/31/2020: Reformatting text as number quickly
Select the entire column and use the Text to Columns tool on the Data tab.  When the tool opens, rather than selecting one of the delimiter or fixed length settings, simply click ‘Finish’.

Justice and Law concept image

Sean O’Shea: Tips for Paralegals and Litigation Support Professionals – December 2019

12/1/2019: D.S.C.: Fact Summaries Withheld Despite Faulty Metadata Review
District of South Carolina allows fact summaries to be withheld even though some determined to be dupes without word by word comparison.

12/2/2019: Java script to convert xls to csv
Simply drag a .js file into a folder, click it, and it will batch convert from xls to csv.

12/3/2019: How to exclude what you’re not searching for
A caret can be used in Regex to indicate which characters should not be returned in search results.


. . . will only find numbers.

Regex image

12/4/2019: Powershell script to split up .csv file
This can be used to break up a large Excel file that won’t open in Excel.

12/5/019: Head’s up! Check your Python modules
There is an imposter version of the popular library dateutill which is called python3-dateutil with a one ‘1’ at the end instead of a lowercase L, ‘l’.

12/6/2019: reStructuredText
you can convert python reStructuredText (.rst) files with a Chrome app.

12/7/2019: Fix for when Windows Media Player Plays Audio but not Video
If Windows Media Player plays the audio but not the video of a mpeg file in Windows 10, VLC should be able to play the video successfully.\

12/8/2019: N.D. Cal.: TRO on CTO for lock out of AWS.
The Court issued a temporary restraining order preventing a Chief Technology Officer from altering source code for Ambitrace, software for tracing sensitive data.

12/9/2019: Bankers Box Ban?
FedEx may reject bankers boxes with openings or those weighing more than 30 pounds.

12/10/2019: Get Smaller, Faster Printing PDFs with Adobe ClearScan
The ClearScan OCR tool creates custom fonts rather than invisible text overlain on images for smaller text searchable files.

12/11/2019: Michigan Court of Appeals: No Bad Faith for Overwriting Interrogation Video
Overwriting of interrogation video by police was found not to be in bad faith by Michigan Court of Appeals, because it was a routine practice.

12/12/2019: Generate X number of entries for values listed with a total count
If you have a spreadsheet listing values (one of each kind) in one column, and a count (‘X’) for those values in an adjacent column, you can generate X number of multiple entries in another column for each value.

Excel Spreadsheet image

12/13/2019: New Rule of Federal Criminal Procedure Points to Guidelines for ESI Production
The notes to the new Federal Rule of Criminal Procedure 16.1 recommend JETWG;s ‘Recommendations for Electronically Store Information (ESI) Discovery Production in Federal Criminal Cases’ as a ESI production guide.

12/15/2019: Javascript to extract email addresses from multiple PDFs
I tested the script and it successfully extracted email addresses from two PDFs.

12/16/2019: Blank page with an OFFENDING COMMAND at the end of your hard copy of a PDF
if you get a blank page at the end of a pdf print-out with an error message referring to an offending command, try disabling the postscript pass through in the advanced settings for the printer.

12/17/2019: District of South Dakota: Forensic Examination Order Granted Where One Month Passes Between Subpoena and IT Email Review
D.S.D. would not require the production of a preservation letter because spoliation was not proven, but it did require the production of documents about the preservation letter because affidavits not sufficiently detailed.

12/18/2019: ACEDS E-Discovery IQ Test
Hint: Not all TAR tools begin with a SME reviewing a seed set.

12/19/2019: Each Emoji Has a Unicode
The standard smiley face emoji appears slightly different across platforms: Apple, Google, Facebook, Windows, Twitter, JoyPixels (an open source emoji designer); Samsung; and Gmail.  Softbank, DoCoMo and KDDI are Japanese mobile phone providers.  All are assigned the unicode 1F600.

Emoji image

12/20/2019: How to Add File Extensions with Bulk Rename Utility
To add an extension to all files in a folder with Bulk rename utility enter the regular expression: (.+) in the Match box, and then \1.pdf in the Replace box

12/21/2019: Your Recipient May Not See Your☺As You Do
Emojis entered in one platform will not be displayed the same way in another platform.

Emjoi email test image Emjoi email test image

12/22/2019: Getting around the 255 character file path limit in Windows 10
A change in registry editor can allow you to exceed the 255 character file path limit in Win 10.

12/23/2019: M.D. Pa.: Departing from Sedona Produces More Heat Than Light
“The parties’ decision to pursue two different and unilateral approaches to resolve this discovery dispute then compounded rather than eliminated these discovery shortcomings.”  Lawson v. Love’s Travel Stops & Country Stories, No. 1:17-CV-1266, 2019 U.S. Dist. LEXIS 219687, at *18 (M.D. Pa. Dec. 2, 2019)

12/24/2019: E.D. Pa.: Expert to Study if French Blocking Statute Applies for ESI in NY Relativity Databases
The Court cited the Sedona Conference’s Working Group 6 standards on cross border discovery as an important authority guiding its decision.

12/25/2019: Unicode Utility
Unicode Utility will help you insert any unicode character in any application.

12/26/2019: FileMaker Pro
FileMaker Pro helps users without programming skills create custom applications.

12/27/2019: Drill Down for Detail in Pivot Tables
You can drill down in a pivot table in Excel to get the rows from the data range used for any one value.

12/28/2019: Data Can Be Recovered From Re-Formatted External Hard Drives with EaseUS
The free trial version of EaseUS will preview lost files that can be recovered, but you need to buy a license to actually begin recovering files.  This does however let you know if there’s something to recover.

12/29/2019: Supreme Court of Wyoming: No Brady Obligation to Search for Buried Data
“To charge prosecutors with knowledge of exculpatory evidence buried in the computer databases of institutions that collect and store vast amounts of digitized data would be an unreasonable extension of the Brady rule.”  Byerly v. State, 2019 Wyo. LEXIS 132, *32 (Wyo. Dec. 27, 2019).Wyo. LEXIS 132 (Wyo. Dec. 27, 2019

Justice and Law concept image

Sean O’Shea: Tips for Paralegals and Litigation Support Professionals – November 2019

10/30/2019: Which law firms have had data breaches?
Jenner & Block; Proskauer; Alston & Bird; Harris Beach; Heller Ehrman; Jones Day; Latham & Watkins; McDermott, Will, & Emery; Mintz Levin; and Wilson Sonsini.

10/31/2019: Cal. Ct. App.: Exclusion of Preservation Letter Not Reversible Error
Exclusion of preservation letter in negligence case where location was destroyed held not to be reversible error by California Court of Appeal.

11/1/2019: -extoff command
You can open a program with add-ins disabled in command prompt by entering the path to the executable followed by -extoff.

11/2/2019: Wildcard search for a string of numbers
In Excel use a MATCH formula with a nested TEXT formula to run a number wildcard search.

Excel Match Formula

11/3/2019: Get Your Attorneys In Synch at Depos with CaseViewNet
If you are connecting with a serial cable, the most common baud rate is 2400.

11/4/2019: Glasswire vs. MyLanViewer
MyLanViewer does a better job of detecting devices on a wifi network than Glasswire.

11/5/2019: Pull from the right until string found
Use this formula in Excel to pull data from the right until string found


11/6/2019: Increase the file size limit on attachments
In registry editor you can change the limit on the file size of attachments that can be sent by Outlook.

11/7/2019: Automatically change animation on all slides
Edit the code to set any animation effect you choose.

11/8/2019: M.D. Fla.: Search Hits in File Fragments Leads to Adverse Inference Instruction
Using proximity searches for key witness names, the examiner was able to find hundreds of relevant hits in fragments of files that had either just been deleted or from those that had been erased.

11/9/2019: TrialWorks – Troubles of New Force in Cloud Based Document Management
TrialWorks fell victim to a ransomware attack.

11/10/2019: Searching metadata fields in Relativity
If you run a keyword index search in Relativity for multiple terms that exist in different fields, no results will be returned.

11/11/2019: formhacker boomarklet
Bookmarklet to edit text on a web page.

If a browser prints a web page to a PDF with link addresses displayed. try the ‘Save as PDF’ add-in for Chrome.

11/13/2019: Turn off Animation in a Presentation
Don’t miss that PowerPoint includes an option under Slide Show . . . Set-up Show to deactivate animated objects.

11/14/2019: Searching across metadata fields
In Relativity, in order to search through metadata fields, create a new dtSearch index based on a saved search with those metadata fields selected

11/15/2019: Rule 45 and Producing ESI More Than 100 Miles Away
SDNY ruling that the 100 mile rule of FRCP 45 doesn’t apply for ESI uploads.

11/16/2019: Conceptual Space Dimensions
Increasing the dimensions of a conceptual space of a Relativity analytics index above 300 will have diminishing returns.

11/17/2019: Documents Errors in Analytics Operations
Documents with:

  1. encrypted text
  2. no text
  3. corrupt text
  4. special characters such as 😎
  5. Email segments > 2000
  6. Metadata fields more than 500 characters

. . . may cause errors in Relativity analytics operations.

11/18/2019: Windows Explorer won’t change directories
Try following the cd command with the operator /d, this will allow the drive and directory to be changed at the same time.

11/19/2019: Recombining split files
use DOS command to recombine split files

copy /b splitfile1.bin + spiltfile2.bin “2019LItSupport.rar”

11/20/2019: Printing out animated objects from a single slide on multiple pages
A macro will place each animated object on a separate slide.

11/21/2019: Goetz’s File Splitter
This free download will allow you to split up files on a set number of KBs in command prompt.

11/22/2019: Total Commander
Use Total Commander to split, rename, and compare files.

11/23/2019: Combine split files with 7-zip
You can use the popular file compression software 7-zip to both split and recombine files.   Simply place the folders you need to recombine in a single folder and then go to File . . . Combine files.  You will need to add the correct extension on to the recombined file.

11/24/2019: Reasonable Suspicion Required For Searches at the Border
1. Mass: Both CBP basic (smartphone internal tools and metadata) and advanced searches (encrypted and deleted data, and copying data) require reasonable suspicion.

11/25/2019: Does jailbreaking alter digital evidence?
iPhones automatically synchronize and download the most recent 50 emails from servers to which they synch.  The emails can only be recovered if an iPhone is jailbroken.

11/26/2019: Select all email addresses in Word
Regex to find emails in Word:


11/27/2019: Set Rows to Repeat at Top of Multiple Worksheets
VBA code to enter setting for rows to repeat at top of all worksheets.