Attachment to Deposition Notice under Rule 30(b)(6)

ATTACHMENT A

Please designate a person or person(s), with knowledge of the following topics:

Identity of IT Personnel

The identity of all employees who were responsible for managing and maintaining the Defendant’s technology and ESI infrastructure;

The identity of all non-employee consultants, consulting firms, contractors (or similar persons/entity) responsible for managing and maintaining the Defendant’s technology and ESI infrastructure.

Inventory of Computer Systems, Databases and Other Sources of ESI at the Defendant’s company:

Numbers, types and locations of servers, workstations and laptops;

Operating systems and software, including dates they were in use;

File naming and location saving conventions;

Identity and status of legacy systems;

Hardware and software modifications;

Description of all employee e-mail accounts;

Description of all cell phones, PDAs, digital convergence devices or other portable electronic devices.

Policies & Procedures for Labeling,...