Seven Elements of Bulletproof Internal Investigations

Quantum’s Jeff Johnson has published the article “Seven Elements of Bulletproof Internal Investigations” in The Metropolitan Corporate Counsel magazine.

This article explains the correlation between the oft-cited goal of Rule 1 of the Federal Rules of Civil Procedure – to provide the “just, speedy and inexpensive determination of every action” – with the triple constraints of the project management triangle (Scope, Time and Cost).

Federal Rules of Civil Procedure


The Proportionality Triangle™ is explained as a strategic model for preparing for discovery negotiations by identifying potential positions and supporting arguments. It also discusses the Proportionality Worksheet and how the Proportionality Triangle can serve as a framework for a structured series of role-playing exercises to sharpen e-discovery negotiating skills.

Propotionality Triangle


Poorly designed and inadequately executed internal investigations today will have significant costs down the road It is crucial to think with the end in mind. So how can IT, legal, and HR professionals consistently work together on internal investigations that stand up to scrutiny later on, even years later? The acronym PROTEST highlights the most critical elements of any internal investigation of electronic information, including email, loose files, and databases.

Preservation – Preserve electronically stored information
Range – What is the scope of the investigation?
Organization – Form and outline a plan in writing.
Team – Engage stakeholders
Execution – Implement the plan.
Chain of Custody & Logs – Document the process
Tools – What tools are needed to execute the plan?


Due to the many ESI collection, processing, search, decryption & TAR options available in any discovery matter, Quantum specializes in consulting with parties from a technical perspective regarding the framework set forth in Federal Rule 26(b)(2) to settle upon an approach that is proportional to the needs of the case, the amount in controversy, the parties’ resources, and the importance of the proposed discovery in the matter.

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Quantum Professional Services Launches Needles SD

The eDisclosure of structured data (“SD”) can be complex…fraught with errors and time-consuming.

Quantum’s software solution – Needles SD – is the result of years of litigation technology practice as we’ve examined the a wide variety of SD sources and their output, from Oracle to MySQL.

Some of the features of Needles SD are the ability to match multiple columns from two data sets, wildcard search, customizable reporting, and very fast processing.

In a recent commercial dispute, Needles SD searched 16 million records with 1800 terms in just a few minutes.

This software is available via Quantum Professional Services.

To get started, contact your representative or simply e-mail


Benefits of Conducting Business Database Discovery

Managing IP magazine has published an article Jeff Johnson co-authored with Brent Babcock of Knobbe Martens Olson & Bear, “Discover Business Databases.” In the article, Babcock and Johnson summarize some of the benefits of pursuing discovery of business databases and offer advice on requesting database discovery.

The article also includes a sidebar in which discusses an interesting case where Quantum found crucial evidence in a 1990’s-era accounting system:

The traditional focus of e-discovery has been to manage unstructured data, such as electronic documents, e-mails, presentations, and spreadsheets. Today, courts and attorneys increasingly recognize that business databases – the informational heart of many organizations – represent a valuable but often untapped discovery resource. In fact, business databases may be the only place where certain information may exist. Obtaining the most meaningful data from databases requires specialized knowledge and tools. However, early assessment of the data potentially contained in such databases can help focus discovery efforts and thereby reduce litigation costs.  IP owners should be aware of the advantages of obtaining discovery of business databases compared to conducting traditional e-discovery of unstructured records.

Quantum offers significant discovery experience across a wide range of practice areas, involving FLSA, wage & hour litigation, intellectual property disputes, insurance claims, data breaches and Sarbanes-Oxley compliance.

Our technologies and methods enable us to execute finely-crafted inquiries into the data.  With over 20 years of experience across many relation-a database management systems and programming languages (including C, C++, C#, Java, .NET, VBA and many more), our development team couples database connectivity protocols with ETL (Extract Transform & Load) tools and processes in order to seamlessly extract and transform structured ESI.

Read the article here: