Sonya-

I stand by the comment- as I said 

"...*IF* IT wanted to establish a set of practices to ensure "every version
and iteration of an electronic record" was deleted, it's *NOT* that
difficult- you eliminate any local storage, store all content on servers
that users cannot delete or save content locally from, backup content from
set time periods, and recycle all of those backups according to a rigid
schedule..."

Likely the reason this didn't happen in the Google/Oracle case is the system
wasn't configured in a way to NOT generate "autosaves" of messages while
being created. (See page 3 of the docket)

"...During discovery, Google listed the final version of this email on its
privilege log, but produced "autosaves" or periodic snapshots of the email
as it was being drafted."

In this case, IT did not configure the system to ensure that either the
'autosaves' were deleted when the final message was completed and sent, or
that the 'autosaves' were periodically purged "in the course of normal
business". 

The biggest blunder however was Google's counsel requesting this information
be provided BY E-MAIL while there was an ongoing case related to the
subject.  Why would anyone, even with the consideration of marking it
"Attorney Work Product- Google Confidential" ask for something like this to
be fully documented if they didn't understand HOW ESI is generated and that
the data map should clearly show 'autosaves' would show up in the product
provided in response to the discovery request?

Larry
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