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Comprehensive List of “Best Practices” Relating to the Forensic Acquisition, Examination, Presentation and Preservation of Computers and Electronically-Stored Data (ESI) in Bankruptcy Cases ©

One should take care and consider the appropriate technical and legal aspects for a debtor case using established digital/computer forensic methodologies. Every debtor case needs to be tailored to the facts and circumstances related to the information technologies used, and this cannot necessarily be pre-fabricated. The specific circumstances will need to be examined on a case-by-case basis by the digital forensic accounting technologist early in the case (before the 341 and/or 2004 exam).

General Rules:

  • Do not turn on, start or use the debtor's computers, PDA or other digital devices
    until the electronically stored information (ESI) has been safeguarded.
  • Always document every step during acquisition, preservation and processing of
    the debtor's ESI.
  • Always gather and analyze the digital evidence in accordance with written polices
    and procedures, allowing for flexibility as may be necessary for the individual
    case.
  • Use current computer forensic hardware and software for examination of the
    debtor's ESI.
  • Be familiar with the forensic tools that you are using to gather or analyze digital
    evidence.

Chain of Evidence:

  • Use and maintain chain-of-custody records during the life of the case for all
    debtor hard drives, PDAs, tape backups and other media and devices.
  • Keep a chronological diary with dates, times and detailed notes as to the
    investigation process.

Acquisition of the Debtor's ESI:

  • Do not allow the writing of any information to the debtor's HDD or digital devices.
  • Do not rely on write-protection software, and always use write-protection
    hardware.
  • Use new/sanitize HDD prior to using for copying/storage of the debtor's forensic image(s).
  • Acquire and secure the forensic image using a cryptographic hash digest value
    for the debtor's HDD and other devices, always preserving the original debtor's
    information.
  • Should the forensic image fail, the destination drive will be wiped (sanitized)
    before re-use.
  • Create multiple forensic images for expanded investigation if necessary.
  • Be prepared for confronting computer viruses and worms early in the case.
  • Maintain adequate forensic software for locating and capturing encrypted
    debtor information.
  • Examine all media sources for possible steganography and/or encrypted files,
    folders and drives.
  • Search forensic image for hidden disk partitions and disk areas early in the case.
  • Examine date settings early in the case.
  • Review possible file backdating early in the case.
  • Create a timeline analysis for the debtor’s ESI found on the forensic images.

Processing the Debtor's ESI:

  • Restore additional forensic image to another sterile drive to have a bootable
    clone if not using forensic software designed for this purpose.
  • Filter e-mail and instant messages by name, subject, key information, text, dates and multiple addresses.
  • Create the combined digital data source ESI from all forensic images for expanded investigation if necessary.
  • Index the debtor's combined digital data source ESI image for each file type/signature.
  • Create and regularly update the combined digital data source ESI for fast searches.
  • Use electronic Bates numbers to identify case facts, files and documents as
    necessary.

Preservation of the Debtor's ESI:

  • Protect and secure the debtor's HDD, PDA, digital devices and media for several years including providing for storage and related environmental safeguard and other conditions.
  • Be prepared to protect and secure the "pristine" image of the debtor's HDD, PDA
    and digital devices for several years including providing for storage and related
    environmental safeguard and other conditions.
  • Use care when moving and examining the debtor's electronic information, and
    document accordingly.

Golden Rule:

  • Never turn on (or off) the debtor's computer or digital devices prior to the digital forensic accounting technologist safeguarding the property of the estate - NEVER.

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