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Analyze the following situation and determine the proper response:

a. Suppose that in the Kuasar Stadium case, your supervising attorney has asked you to draft a set of interrogatories to be sent to The Kuasar Management Corporation, the object of which is to lay the foundation for a later document-production request related to all ESI stored in the corporation’s computer system. One set of interrogatories would have to attempt to determine the number and types of computers that are in operation as a part of the corporation’s daily routine. How would you phrase the interrogatories to ensure that no computers escape consideration?

b. Another set of questions would attempt to determine the configuration of the corporation’s e-mail system. What questions would you consider asking about the e-mail system?

c. Another set of questions would aim to obtain the names and a list of responsibilities of all individuals who are in any way involved in maintaining or servicing the corporation’s computer system and any network systems that are a part of the corporation’s operation. List the types of individuals who would have to be included in this question.

d. Another set of questions would have to deal with the computer records themselves. What types of questions would you have to ask about these records?

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