- always consider the date integrity issue when planning an e-discovery project
- try to identify and process custodial files using the "appropriate" or designated time zone
- if designating an arbitrary time zone for a global collection (eg GMT), ensure all parties are aware of the impact of the decision
- because of the way inconsistent way in which portable computing devices and calendar applications are set up with respect to date and time, even native date and time stamps can be unreliable evidence without expert testimony.
For example, if a user resides in Toronto and has an appointment set for 3pm in her Blackberry calendar, but her meeting is in Vancouver, the time might be set as 3pm or 6pm, depending on what application is being used and how time options are selected.o edit.