Preserving, authenticating, analyzing, and accurately producing data from enterprise databases requires special skills and methodologies. Stroz Friedberg has led the field in this area, handling matters involving all such tasks relating to enterprise databases used by insurance, financial, design, telemarketing, and consumer electronics companies. Our work has enabled clients to comply with grand jury subpoenas and document requests, to demonstrate the ease or difficulty of such compliance where burden is at issue, to authenticate database output for use in a trial, and to identify problems with database schema, front-end reports, or workflows that are causing the database output to be wrong.
Preservation. Most often, enterprise databases are so large, dynamic, and complex that they cannot be copied, key-word searched, and produced in the same manner as email or e-documents. Indeed, a complete copy of an enterprise database will normally not open or run on anything short of an exact replica of the hardware and software on which the database resides. Accordingly, preservation efforts must normally leverage the infrastructure of the database itself, using a combination of disabling archive and deletion features, preserving backup tapes, and/or preserving existing reports.
Analysis. Analyzing the authenticity of database output can involve the empirical testing of actual versus expected results, examining and validating database workflow (including third-party components), the underlying relational logic (i.e., how the database has been structured to operate upon the data it receives), the layout of the database schema, and the queries that produced the reports. Flaws at any of the stages can produce faulty output, meaning that the data in reports does not accurately reflect the business transactions or information it was meant to summarize.
Production. Sometimes, it is data retrieval and production, not authenticity, that is at issue. The database may not be structured to easily access the data that must be produced and a combination of legal understanding and technical skill must be applied in order to translate the legal production requirements into technical queries and actions. Specifically, after familiarity with the database structure is gained, standard or custom reports must be run against the database to extract the relevant, requested information. In cases where the data cannot be retrieved in the requested form or without undue burden, it is essential that the examiner have sufficient qualifications and a reputation for integrity to assure the adversary or finder of the conclusions and opinions presented. Similarly, when results of database queries are produced, the examiner must engender confidence that full and accurate results are being produced. This combination of legal understanding, technical skill, and a methodology that relies on transparency and assurance has enabled Stroz Friedberg to assist many clients in making complex productions from enormous, multi-year databases in highly contentious matters.