Referral Needed: Expert Regarding Forensic Authenticity of Electronic Documents/Files
Anyone had occasion or need to use an expert to forensically evaluate and
testify regarding the authenticity of electronic documents? We have a case
going to trial next month in which the opposing party has recently produced
electronic documents (PDFs) that, upon scrutiny, have clearly been
fabricated or "doctored":
- One is a subcontract created in Word-by our opposing counsel, no
less-a day before its production, in which he screenshotted signatures onto
it from another subcontract. - Twenty-one others are Home Depot invoices to which he (or his client
or someone else) added (or in which he changed) a reference to the subject
project in the invoices' "Job Description" field, i.e., in order to falsely
make it appear that the invoiced materials were delivered to the subject
project (when our contention is that they were not).
Obviously, our opposing counsel is not a member of this committee or list,
so we have no compunction against floating this request here.
Let us know of any referrals/recommendations.
Bryan L. Capps, Esq.
Board Certified in Construction Law by The Florida Bar
The Construction Law Firm
P.O. Box 560693
Orlando, FL 32856
(407) 674-0674
(407) 808-0098
mailto:bcapps@theconstructionlawfirm.com
bcapps@theconstructionlawfirm.com
http://www.theconstructionlawfirm.com/ www.theconstructionlawfirm.com
Offices: Orlando
[cid:image002.png@01D9D1EF.D56D0160]
Lauren Abeyta, Founder & Chief Operating Officer
Construction Discovery Experts
Direct: 214.616.8998tel:Direct:+214.616.8998
labeyta@cdelegal.commailto:labeyta@cdelegal.com | www.cdelegal.comhttps://urldefense.com/v3/__http:/www.cdelegal.com/__;!!CUnmew!8ylJfpBAaB_Zya-aCiMaQtWnrKmNy2YnfheAdaaB3IfhGr2SuF8ApvuGvhdFzqzkVMzQohn_DRnCros$
David J. Ehrlich │ Senior Corporate Counsel
Board Certified in Construction Law by The Florida Bar
Turner Construction Company │ Florida
mobile 321.417.2551 │ dehrlich@tcco.commailto:dehrlich@tcco.com
websitehttp://www.turnerconstruction.com/ │ linkedinhttps://www.linkedin.com/company/turner-construction-company/mycompany/ │ facebookhttps://www.facebook.com/turnerconstruction │ twitterhttps://urldefense.proofpoint.com/v2/url?u=https-3A__twitter.com_turner-5Ftalk&d=DwMF3g&c=sb6gdlHSSEAKVs7mNNqH8g&r=BTfzIaG7Dt7qCwL_FV6HS8_S_aEXUzda5rKULBFmvrU&m=jKPf8WDjPuxETyI5V4Jd0WhMUYfgA_ft4zzefHHwsl4&s=HPizB5-B_rPGA_mVbb23xZ5O8Po1ZNk1ORF6IUWoMtE&e= │ youtubehttps://urldefense.proofpoint.com/v2/url?u=http-3A__www.youtube.com_user_turnerconstructionco-3Ffeature-3Dresults-5Fmain&d=DwMF3g&c=sb6gdlHSSEAKVs7mNNqH8g&r=BTfzIaG7Dt7qCwL_FV6HS8_S_aEXUzda5rKULBFmvrU&m=jKPf8WDjPuxETyI5V4Jd0WhMUYfgA_ft4zzefHHwsl4&s=-I92KyfkEOvEJHkN5M8QRkNcNGdQHRG549X9kWNEK6U&e=
[Construction Law Board Certification logo, black and white] [CLSA Fellow_thumb]
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From: clc-discussion-bounces@lists.flabarrpptl.org clc-discussion-bounces@lists.flabarrpptl.org On Behalf Of RPPTL CLC-Discussion
Sent: Friday, August 18, 2023 4:05 PM
To: clc-discussion@lists.flabarrpptl.org
Subject: [CLC-Discussion] Referral Needed: Expert Regarding Forensic Authenticity of Electronic Documents/Files
EXTERNAL EMAIL - Please Handle Cautiously
Anyone had occasion or need to use an expert to forensically evaluate and testify regarding the authenticity of electronic documents? We have a case going to trial next month in which the opposing party has recently produced electronic documents (PDFs) that, upon scrutiny, have clearly been fabricated or "doctored":
- One is a subcontract created in Word-by our opposing counsel, no less-a day before its production, in which he screenshotted signatures onto it from another subcontract.
- Twenty-one others are Home Depot invoices to which he (or his client or someone else) added (or in which he changed) a reference to the subject project in the invoices' "Job Description" field, i.e., in order to falsely make it appear that the invoiced materials were delivered to the subject project (when our contention is that they were not).
Obviously, our opposing counsel is not a member of this committee or list, so we have no compunction against floating this request here.
Let us know of any referrals/recommendations...
Bryan L. Capps, Esq.
[Logo Description automatically generated with medium confidence]
Board Certified in Construction Law by The Florida Bar
The Construction Law Firm
P.O. Box 560693
Orlando, FL 32856
[cid:image012.png@01D9D1EF.D56D0160]
(407) 674-0674
(407) 808-0098
[cid:image014.png@01D9D1EF.D56D0160]
bcapps@theconstructionlawfirm.commailto:bcapps@theconstructionlawfirm.com
[cid:image015.png@01D9D1EF.D56D0160]
www.theconstructionlawfirm.comhttps://urldefense.com/v3/__http:/www.theconstructionlawfirm.com/__;!!CUnmew!8GIkLSK87f8gGTz-JXLlFRyJ61CSXspzOnKuqTNUFgR70ct_CDN8tO8BicI-9Tx3PAbr_UYfyvvQQgv6L4-erra2BerNsW-h$
Offices: Orlando
Brett Lamb, Construction Discovery Experts. See attached contact information.
From: clc-discussion-bounces@lists.flabarrpptl.org clc-discussion-bounces@lists.flabarrpptl.org On Behalf Of RPPTL CLC-Discussion
Sent: Friday, August 18, 2023 4:05 PM
To: clc-discussion@lists.flabarrpptl.org
Subject: [CLC-Discussion] Referral Needed: Expert Regarding Forensic Authenticity of Electronic Documents/Files
Anyone had occasion or need to use an expert to forensically evaluate and testify regarding the authenticity of electronic documents? We have a case going to trial next month in which the opposing party has recently produced electronic documents (PDFs) that, upon scrutiny, have clearly been fabricated or "doctored":
- One is a subcontract created in Word-by our opposing counsel, no less-a day before its production, in which he screenshotted signatures onto it from another subcontract.
- Twenty-one others are Home Depot invoices to which he (or his client or someone else) added (or in which he changed) a reference to the subject project in the invoices' "Job Description" field, i.e., in order to falsely make it appear that the invoiced materials were delivered to the subject project (when our contention is that they were not).
Obviously, our opposing counsel is not a member of this committee or list, so we have no compunction against floating this request here.
Let us know of any referrals/recommendations...
Bryan L. Capps, Esq.
[Logo Description automatically generated with medium confidence]
Board Certified in Construction Law by The Florida Bar
The Construction Law Firm
P.O. Box 560693
Orlando, FL 32856
[cid:image003.png@01D9D1F0.4B34FBA0]
(407) 674-0674
(407) 808-0098
[cid:image005.png@01D9D1F0.4B34FBA0]
bcapps@theconstructionlawfirm.commailto:bcapps@theconstructionlawfirm.com
[cid:image006.png@01D9D1F0.4B34FBA0]
www.theconstructionlawfirm.comhttp://www.theconstructionlawfirm.com/
Offices: Orlando
This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed. If you are not the intended recipient, you are hereby notified that any disclosure, copying, or distribution of all or part of the transmitted information is strictly prohibited. If you have received this transmission in error, please notify the sender immediately by responding to this transmission. Thank you.
No recommendations - but please let us know how this turns out!
Denise
Denise Morris Hammond, Esquire
HAMMOND LAW
2115 Lakeside Drive
Orlando, Florida 32803
407-963-3475
dmhammond6@gmail.com

A society grows great when old men plant trees in whose shade they know they will never sit.
~Greek Proverb
On Aug 18, 2023, at 4:23 PM, RPPTL CLC-Discussion clc-discussion@lists.flabarrpptl.org wrote:
Brett Lamb, Construction Discovery Experts. See attached contact information.
From: clc-discussion-bounces@lists.flabarrpptl.org mailto:clc-discussion-bounces@lists.flabarrpptl.org <clc-discussion-bounces@lists.flabarrpptl.org mailto:clc-discussion-bounces@lists.flabarrpptl.org> On Behalf Of RPPTL CLC-Discussion
Sent: Friday, August 18, 2023 4:05 PM
To: clc-discussion@lists.flabarrpptl.org mailto:clc-discussion@lists.flabarrpptl.org
Subject: [CLC-Discussion] Referral Needed: Expert Regarding Forensic Authenticity of Electronic Documents/Files
Anyone had occasion or need to use an expert to forensically evaluate and testify regarding the authenticity of electronic documents? We have a case going to trial next month in which the opposing party has recently produced electronic documents (PDFs) that, upon scrutiny, have clearly been fabricated or “doctored”:
One is a subcontract created in Word—by our opposing counsel, no less—a day before its production, in which he screenshotted signatures onto it from another subcontract.
Twenty-one others are Home Depot invoices to which he (or his client or someone else) added (or in which he changed) a reference to the subject project in the invoices’ “Job Description” field, i.e., in order to falsely make it appear that the invoiced materials were delivered to the subject project (when our contention is that they were not).
Obviously, our opposing counsel is not a member of this committee or list, so we have no compunction against floating this request here.
Let us know of any referrals/recommendations…
Bryan L. Capps, Esq.
<image002.png>
Board Certified in Construction Law by The Florida Bar
The Construction Law Firm
P.O. Box 560693
Orlando, FL 32856
<image003.png>
(407) 674-0674
<image004.png>
(407) 808-0098
<image005.png>
bcapps@theconstructionlawfirm.com mailto:bcapps@theconstructionlawfirm.com
<image006.png>
www.theconstructionlawfirm.com http://www.theconstructionlawfirm.com/
Offices: Orlando
This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed. If you are not the intended recipient, you are hereby notified that any disclosure, copying, or distribution of all or part of the transmitted information is strictly prohibited. If you have received this transmission in error, please notify the sender immediately by responding to this transmission. Thank you.
<Brett Lamb.vcf>_______________________________________________
CLC-Discussion mailing list
CLC-Discussion@lists.flabarrpptl.org mailto:CLC-Discussion@lists.flabarrpptl.org
http://mailman.fsr.com/mailman/listinfo/clc-discussion
John Sawicki handles these types of matters. He is also an attorney.
https://www.forensicdatacorp.com/about
[cabd61_3f896e1738cc4736881210c8006b199a.png]
ABOUThttps://www.forensicdatacorp.com/about
forensicdatacorp.comhttps://www.forensicdatacorp.com/about
Keith Bell | Shareholder
kbell@clarkpartington.commailto:kbell@clarkpartington.com | Office: (850) 320-6838callto:(850)%20320-6838 | Cell: (850) 261-0932callto:(850)%20261-0932
CLARK PARTINGTON
Office: (850) 597-7483 | Fax: (850) 597-7591
215 South Monroe Street, Suite 530
Tallahassee, Florida 32301-1804
clarkpartington.comhttps://clarkpartington.com/
[cid:logo4_b42e80e0-c9d5-4d9a-b7eb-3ec959196ec6.jpg]http://clarkpartington.com/
On Aug 18, 2023, at 5:14 PM, RPPTL CLC-Discussion clc-discussion@lists.flabarrpptl.org wrote:
No recommendations - but please let us know how this turns out!
Denise
Denise Morris Hammond, Esquire
HAMMOND LAW
2115 Lakeside Drive
Orlando, Florida 32803
407-963-3475
dmhammond6@gmail.com
<Screen Shot 2020-12-07 at 1.57.41 PM.png>
A society grows great when old men plant trees in whose shade they know they will never sit.
~Greek Proverb
On Aug 18, 2023, at 4:23 PM, RPPTL CLC-Discussion clc-discussion@lists.flabarrpptl.org wrote:
Brett Lamb, Construction Discovery Experts. See attached contact information.
From: clc-discussion-bounces@lists.flabarrpptl.orgmailto:clc-discussion-bounces@lists.flabarrpptl.org <clc-discussion-bounces@lists.flabarrpptl.orgmailto:clc-discussion-bounces@lists.flabarrpptl.org> On Behalf Of RPPTL CLC-Discussion
Sent: Friday, August 18, 2023 4:05 PM
To: clc-discussion@lists.flabarrpptl.orgmailto:clc-discussion@lists.flabarrpptl.org
Subject: [CLC-Discussion] Referral Needed: Expert Regarding Forensic Authenticity of Electronic Documents/Files
Anyone had occasion or need to use an expert to forensically evaluate and testify regarding the authenticity of electronic documents? We have a case going to trial next month in which the opposing party has recently produced electronic documents (PDFs) that, upon scrutiny, have clearly been fabricated or “doctored”:
- One is a subcontract created in Word—by our opposing counsel, no less—a day before its production, in which he screenshotted signatures onto it from another subcontract.
- Twenty-one others are Home Depot invoices to which he (or his client or someone else) added (or in which he changed) a reference to the subject project in the invoices’ “Job Description” field, i.e., in order to falsely make it appear that the invoiced materials were delivered to the subject project (when our contention is that they were not).
Obviously, our opposing counsel is not a member of this committee or list, so we have no compunction against floating this request here.
Let us know of any referrals/recommendations…
Bryan L. Capps, Esq.
<image002.png>
Board Certified in Construction Law by The Florida Bar
The Construction Law Firm
P.O. Box 560693
Orlando, FL 32856
<image003.png>
(407) 674-0674
<image004.png>
(407) 808-0098
<image005.png>
bcapps@theconstructionlawfirm.commailto:bcapps@theconstructionlawfirm.com
<image006.png>
Offices: Orlando
This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed. If you are not the intended recipient, you are hereby notified that any disclosure, copying, or distribution of all or part of the transmitted information is strictly prohibited. If you have received this transmission in error, please notify the sender immediately by responding to this transmission. Thank you.
<Brett Lamb.vcf>_______________________________________________
CLC-Discussion mailing list
CLC-Discussion@lists.flabarrpptl.orgmailto:CLC-Discussion@lists.flabarrpptl.org
https://link.edgepilot.com/s/4276ad44/TQv03FbJf0W3dee1B7w22w?u=http://mailman.fsr.com/mailman/listinfo/clc-discussion
CLC-Discussion mailing list
CLC-Discussion@lists.flabarrpptl.org
https://link.edgepilot.com/s/4276ad44/TQv03FbJf0W3dee1B7w22w?u=http://mailman.fsr.com/mailman/listinfo/clc-discussion
I presume/hope that upon confirmation of the shenanigans, a Bar complaint and permanent disbarment follow.
[cid:constructionlaw_7ab6c3d7-3a03-4936-8963-fa75b9540868.png] Robert Doan
Board Certified Construction Attorney
Supreme Court Certified Circuit Civil Mediator
Cobb Cole
231 North Woodland Boulevard
DeLand, FL 32720
(D) 386-736-7700 | (F) 386-785-1549
Websitehttps://cobbcole.com/ | Biohttps://cobbcole.com/attorney/robert-e-doan/
From: clc-discussion-bounces@lists.flabarrpptl.org clc-discussion-bounces@lists.flabarrpptl.org On Behalf Of RPPTL CLC-Discussion
Sent: Friday, August 18, 2023 4:05 PM
To: clc-discussion@lists.flabarrpptl.org
Subject: [CLC-Discussion] Referral Needed: Expert Regarding Forensic Authenticity of Electronic Documents/Files
Anyone had occasion or need to use an expert to forensically evaluate and testify regarding the authenticity of electronic documents? We have a case going to trial next month in which the opposing party has recently produced electronic documents (PDFs) that, upon scrutiny, have clearly been fabricated or "doctored":
- One is a subcontract created in Word-by our opposing counsel, no less-a day before its production, in which he screenshotted signatures onto it from another subcontract.
- Twenty-one others are Home Depot invoices to which he (or his client or someone else) added (or in which he changed) a reference to the subject project in the invoices' "Job Description" field, i.e., in order to falsely make it appear that the invoiced materials were delivered to the subject project (when our contention is that they were not).
Obviously, our opposing counsel is not a member of this committee or list, so we have no compunction against floating this request here.
Let us know of any referrals/recommendations...
Bryan L. Capps, Esq.
[cid:image007.png@01D9D27B.1FBA6560]
Board Certified in Construction Law by The Florida Bar
The Construction Law Firm
P.O. Box 560693
Orlando, FL 32856
[cid:image003.png@01D9D27B.1FA57DD0]
(407) 674-0674
(407) 808-0098
[cid:image005.png@01D9D27B.1FA57DD0]
bcapps@theconstructionlawfirm.commailto:bcapps@theconstructionlawfirm.com
[cid:image006.png@01D9D27B.1FA57DD0]
www.theconstructionlawfirm.comhttp://www.theconstructionlawfirm.com/
Offices: Orlando
While this does not directly answer the question asked, the CLC members should consider attending the UF E-Discovery program this year.
There is a virtual option and 14 FREE CLE hours -along with great content - completely free.
This is a link to last years program and I believe the 2024 program is already scheduled for February.
10th Annual UF Law E-Discovery Conference (ufediscoveryconference.com)https://ufediscoveryconference.com/
I have attended the last two years - and at least 1-2 hours have focused on construction law issues specifically.
Go Gators!
Paul J. Kelly
Paul J. Kelly, P.A.
2959 First Avenue North
St. Petersburg, Florida 33713
[Board Certified Construction Logo]
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From: clc-discussion-bounces@lists.flabarrpptl.org clc-discussion-bounces@lists.flabarrpptl.org On Behalf Of RPPTL CLC-Discussion
Sent: Saturday, August 19, 2023 8:57 AM
To: clc-discussion@lists.flabarrpptl.org
Subject: Re: [CLC-Discussion] Referral Needed: Expert Regarding Forensic Authenticity of Electronic Documents/Files
I presume/hope that upon confirmation of the shenanigans, a Bar complaint and permanent disbarment follow.
[Picture1.png]
Robert Doan
Board Certified Construction Attorney
Supreme Court Certified Circuit Civil Mediator
Cobb Cole
231 North Woodland Boulevard
DeLand, FL 32720
(D) 386-736-7700 | (F) 386-785-1549
Websitehttps://cobbcole.com/ | Biohttps://cobbcole.com/attorney/robert-e-doan/
From: clc-discussion-bounces@lists.flabarrpptl.orgmailto:clc-discussion-bounces@lists.flabarrpptl.org <clc-discussion-bounces@lists.flabarrpptl.orgmailto:clc-discussion-bounces@lists.flabarrpptl.org> On Behalf Of RPPTL CLC-Discussion
Sent: Friday, August 18, 2023 4:05 PM
To: clc-discussion@lists.flabarrpptl.orgmailto:clc-discussion@lists.flabarrpptl.org
Subject: [CLC-Discussion] Referral Needed: Expert Regarding Forensic Authenticity of Electronic Documents/Files
Anyone had occasion or need to use an expert to forensically evaluate and testify regarding the authenticity of electronic documents? We have a case going to trial next month in which the opposing party has recently produced electronic documents (PDFs) that, upon scrutiny, have clearly been fabricated or "doctored":
- One is a subcontract created in Word-by our opposing counsel, no less-a day before its production, in which he screenshotted signatures onto it from another subcontract.
- Twenty-one others are Home Depot invoices to which he (or his client or someone else) added (or in which he changed) a reference to the subject project in the invoices' "Job Description" field, i.e., in order to falsely make it appear that the invoiced materials were delivered to the subject project (when our contention is that they were not).
Obviously, our opposing counsel is not a member of this committee or list, so we have no compunction against floating this request here.
Let us know of any referrals/recommendations...
Bryan L. Capps, Esq.
[Logo Description automatically generated with medium confidence]
Board Certified in Construction Law by The Florida Bar
The Construction Law Firm
P.O. Box 560693
Orlando, FL 32856
[cid:image011.png@01D9D287.3C579150]
(407) 674-0674
(407) 808-0098
[cid:image013.png@01D9D287.3C579150]
bcapps@theconstructionlawfirm.commailto:bcapps@theconstructionlawfirm.com
[cid:image014.png@01D9D287.3C579150]
www.theconstructionlawfirm.comhttp://www.theconstructionlawfirm.com/
Offices: Orlando
It appears that the Bar complaint is obligatory, and disbarment indeed
appears to be the Florida Supreme Court's default penalty under such
circumstances.
Bryan L. Capps, Esq.
Board Certified in Construction Law by The Florida Bar
The Construction Law Firm
P.O. Box 560693
Orlando, FL 32856
(407) 674-0674
(407) 808-0098
mailto:bcapps@theconstructionlawfirm.com
bcapps@theconstructionlawfirm.com
http://www.theconstructionlawfirm.com/ www.theconstructionlawfirm.com
Offices: Orlando
From: clc-discussion-bounces@lists.flabarrpptl.org
clc-discussion-bounces@lists.flabarrpptl.org On Behalf Of RPPTL
CLC-Discussion
Sent: Saturday, August 19, 2023 8:57 AM
To: clc-discussion@lists.flabarrpptl.org
Subject: Re: [CLC-Discussion] Referral Needed: Expert Regarding Forensic
Authenticity of Electronic Documents/Files
I presume/hope that upon confirmation of the shenanigans, a Bar complaint
and permanent disbarment follow.
Robert Doan
Board Certified Construction Attorney
Supreme Court Certified Circuit Civil Mediator
Cobb Cole
231 North Woodland Boulevard
DeLand, FL 32720
(D) 386-736-7700 | (F) 386-785-1549
Website https://cobbcole.com/ | Bio
https://cobbcole.com/attorney/robert-e-doan/
From: clc-discussion-bounces@lists.flabarrpptl.org
mailto:clc-discussion-bounces@lists.flabarrpptl.org
<clc-discussion-bounces@lists.flabarrpptl.org
mailto:clc-discussion-bounces@lists.flabarrpptl.org > On Behalf Of RPPTL
CLC-Discussion
Sent: Friday, August 18, 2023 4:05 PM
To: clc-discussion@lists.flabarrpptl.org
mailto:clc-discussion@lists.flabarrpptl.org
Subject: [CLC-Discussion] Referral Needed: Expert Regarding Forensic
Authenticity of Electronic Documents/Files
Anyone had occasion or need to use an expert to forensically evaluate and
testify regarding the authenticity of electronic documents? We have a case
going to trial next month in which the opposing party has recently produced
electronic documents (PDFs) that, upon scrutiny, have clearly been
fabricated or "doctored":
- One is a subcontract created in Word-by our opposing counsel, no
less-a day before its production, in which he screenshotted signatures onto
it from another subcontract. - Twenty-one others are Home Depot invoices to which he (or his client
or someone else) added (or in which he changed) a reference to the subject
project in the invoices' "Job Description" field, i.e., in order to falsely
make it appear that the invoiced materials were delivered to the subject
project (when our contention is that they were not).
Obviously, our opposing counsel is not a member of this committee or list,
so we have no compunction against floating this request here.
Let us know of any referrals/recommendations.
Bryan L. Capps, Esq.
Board Certified in Construction Law by The Florida Bar
The Construction Law Firm
P.O. Box 560693
Orlando, FL 32856
(407) 674-0674
(407) 808-0098
mailto:bcapps@theconstructionlawfirm.com
bcapps@theconstructionlawfirm.com
http://www.theconstructionlawfirm.com/ www.theconstructionlawfirm.com
Offices: Orlando
Yes, the UF e-Discovery program is terrific and registration is free! Here is some information re: next year's conference:
The 11th Annual UF Law E-Discovery Conference is leaping forward virtually and in person on Feb 28-29, 2024, in Gainesville, FL. Get ready to explore cutting-edge strategies, technologies, and best practices that empower legal professionals to excel in the digital landscape.
Contact Prof. William Hamilton or Maribel Rivera (conference organizer) or Google UF e-Discovery for more details.
Best regards, Leslie O'Neal
This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed. If you are not the intended recipient, you are hereby notified that any disclosure, copying, or distribution of all or part of the transmitted information is strictly prohibited. If you have received this transmission in error, please notify the sender immediately by responding to this transmission. Thank you.