Answer the below questions in paragraph format and number your answer for each question. Do not forget to number your answers for each question!

Scenario: The Data Breach Class Action

Your firm is defending a large healthcare provider in a data breach class action involving thousands of patients' records being accessed without authorization. The case involves HIPAA compliance, and multiple departments and custodians hold relevant data.

Questions:

Custodian Interviews: Interviews are planned with custodians from IT security, compliance, legal, and patient records management.

1. How do you prioritize which custodians to interview first, and what special considerations are needed given the sensitivity of the data involved?
2. How would you document potential data locations and systems mentioned during the interviews? Collection Best Practices: One of the systems mentioned during interviews is a legacy database without clear export tools. The IT department suggests screenshots or printed logs.
3. What risks are involved with this method of data collection?
4. What alternative approaches could you recommend to ensure integrity and searchability? ESI Protocols: Plaintiffs propose a broad keyword search list including patient names and internal terms like "flagged account," which may return thousands of irrelevant results.
5. What negotiation strategies would you suggest to refine or challenge this search criteria?
6. What ESI protocol provisions should be proposed to address data volume, relevance, and privacy concerns?