Category Archives: Technology
Amended FRCP 37(e) Provides Rules Governing ESI Preservation and Sanctions
Amended Rule 37(e) of the Federal Rules of Civil Procedure (“FRCP”), effective as of December 1, 2015, squarely addresses sanctions for the spoliation of electronically stored information (“ESI”) and overrules Second Circuit jurisprudence in the area. Some commentators have called FRCP 37(e) the most significant rule governing eDiscovery since the Zubulake line of cases. Prior to the adoption of FRCP 37(e), there existed a split among the Circuits as to the grounds for sanctions arising from the spoliation of ESI. In 2002, in Residential Funding Corp. v. DeGeorge Fin. Corp., 306 F.3d 99 (2d Cir. 2002), the U.S. Court of […]
Gestures Increase Productivity on the iPad
While “giving the finger” is generally frowned upon in a civilized society, the use of multi-finger gestures can increase productivity on the iPad. In October 2011, Apple released an upgrade to iOS, iOS 5, which officially incorporated the use of multi-finger gestures. Once mastered, these gestures nearly eliminate the need to press the Home Button and significantly speed moving between and closing applications. By now you have likely mastered using two fingers to zoom in and out and move between the Home Screens, and double tapping to zoom. With a little practice, you will master these multi-finger gestures and never […]
