• The Inventory. Defense requests a complete inventory of all items taken that may contain any type of digital data, whether or not such items were examined or copied by prosecution’s experts.
• Items the Defense Will Supply to Assist in Getting the Discovery. Defense will provide sanitized hard drives for the forensic copies if requested by the law enforcement agency.
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Specifying the Forensic Copy Format. The preferred format for forensic images is EnCase (E01) Expert Witness Format. However, any forensically sound format is acceptable. (Expert Witness Format is a widely used format that can be opened by the majority of forensic tools available. It is also easily converted into other formats. Finally, it is a self-contained set of files that are not subject to contamination.)
• Specifying Other Formats. Defense requests that any items provided to the prosecution in electronic format including but not limited to call detail records, audio or video recordings, and GPS logs, be provided in the same format to the defense.
• Requesting Supplemental Documents. Defense requests a complete copy of all forensics reports, chain of custody records, and lab notes generated by the prosecution’s experts pertaining to the acquisition, preservation, analysis, and/or reporting by said experts in the course of this investigation.
Defense also requests a copy of the resume or curriculum vitae of any prosecution expert involved in the collection, handling, imaging, or examination of any electronic evidence and or items collected.
• Computers and Related Items. Defense requests a duplicate of any forensic copies made by the prosecution’s experts of any computer hard drive, digital storage media, including but not limited to CD-ROMs, USB flash drives, floppy disks, memory cards, digital camera storage, smart cards, and portable hard drives.
• Cell Phones, GPS Devices, and Other Portable Devices. Defense requests duplicates of any forensic copies made by the prosecution’s experts of any cell phone and/or SIM cards, media cards, GPS devices, media players, game consoles, video recording devices, audio recording devices, or any other electronic devices collected in this case.
• Items Collected and Not Forensically Imaged. In the event the prosecution’s experts did not make a forensic copy of any original media, defense requests that forensically sound copies be made and furnished to the defense for examination by the defense expert.
In the event the prosecution’s experts are unable to make forensic copies of any evidence, the defense requests access to said evidence in order to make forensic copies for examination.