question this case isn't unusual for us i can determine that we have been required to produce our computers and by our i'm speaking pretty broadly we don't own the faster computer to somebody else most of the cases involve the scenario where because if i deliberately do not take something from my computer and produce it to you it's just the same is it you have to trust me when the other side tells me i want production from my work files through the construction site if i don't take something  proving something off for example at the end of the week the shows that have that would be paper relative to the game plan he wanted and enough to produce that i could i suppose i could cheat not produce it i mean i would hope most but most lawyers know not to do that i think most part is known not to do that in this you do and i'm not sure that that's possible to show mine to my computer running when i turn it off or they could show they could show that i could access my i send my email to my sister this morning at such and such a time feasibly they did but beyond that the information that the point the said the court said it should have been filed with a motion for reconsideration hope that this is this was not a summary judgment hearing or a motion to dismiss where there is some definitive point this is an ongoing discovery process and i don't believe coun ask us to search our own computer either way even though the searches for nothing more than impeachment that they admitted that they don't have anything in here that substantive on the case it's going to involve experts and experts and computers are one of the conditions does it out as the discovery out of the way the likely benefit taking into account the amount of controversy the resources of the pardons and the reports of the issue in litigation and the expedition she understood that computers are very relevant to this litigation because he is a computer programmer spends a good deal of this time on thief but she was going to reject the request but she give us  abilities have been impaired he has trouble working now he gets to work later since the accident he has to teach at work since the accident it takes him long to work on any particular project based upon complexity of the project that he was doing well i think that might be the next step in the argument after that we see the evidence i think the first step is just to say is this true he doesn't punch a clock his supervisor at work has said that if he gets great reviews he seems to be doing better and yet he tells me that he has these difficulties were getting very is it mixed isn't there another way you can get this evidence i side records that are used your opponent said you have to for him after the doctors reports i mean can't you get this information some other way trying to trying to invade the privacy somebodies private computer well now we can track people down with their computers well i think but let's back just a minute i understand your question i do want to answer that but if the plaintiffs if we have access to this information this particular it's daily and it's very detailed and he says his stuff we'll have testimony that maybe he hasn't stopped maybe he's still doing this if he is researching these pacific terms and we're not saying any term we've listed in a protective order a few terms icepick headache i'm balanced i q these are things that didn't show up in his medical records and he's where he's been reporting them is he still reporting them i think that might be fair game what the search does not do is have a wholesale access to this computer to call any information the search is very tailored the search basically is comprised of ten steps so this is likewise with computers would be an issue if he was an elementary school teacher but the problem is he says he is now cognitively impaired his tools of his trade everything he does not everything that's an exaggeration but he and the creation of a mirror image is to prevent the destruction of any data or to mess up anything on the original this is what and in the old days we would gather that and tendered what has changed that makes it now ok for you to look through my things as opposed to me to look through my things and and tender what has been requested what part of this is i don't discovery in the state of illinois in people's computers because you're searching terms don't you have to have a reason to know that that individual is searching terms before you ask for this  reason to you know i don't know to tell you you have to have some basis for asking someone to turn over their computer to determine whether or not they're searching specific medical terms you can't just say well you know he has a blog and he's saying that he had ice pick headache on their tour who must be searching that what is your basis and wonder what's going to be the basis that every other defense attorney in the state of illinois for asking for of this is putting the cart before the horse of course people might look of their symptoms does it mean they don't have them but it certainly could mean that they are creating them equal a but do you should be this is the point is don't you have to have some type headache for example is it's not common parlance it's not i have a migraine headache we want to know if plaintiff is listed in all of these symptoms that we have difficulty because you're not off the hook keep going i don't mean to cut you off but even if that's all true where's your belief in good faith that that search took place on this computer or any one of the five computers why d say someone told me that a friend told me whatever i went to the public library and looked up ice pick tell my son he had an ice pick it was sticking in the side of my hand and i mean i guess you were  keep driving at is you can ask which disclosure has to use threshold to invade someone's personal privacy and as i understand from  opposing counsel there's no protocol here there's no specificity that they're looking for and why that is relevant material to this case and why i expect to find it there i mean it goes back to the classic example of what say fishing expedition i don't know that he used his computer to look up symptoms and yet you say i want to go see if it's there how about this i think how did you get discovery question in a deposition how did you come up with the term i you determine that prior to computers how the prior to the opportunity didn't break somebodies privacy i guess that's the way i would i would start with some discovery some deposition discovery to determine if you  court entered its order plaintiffs did not seek to reconsider that discovery order to immediately filed a motion basically said by being friendly content that at that time the court said   turning over the computer for this inspection why didn't you go to baxter earlier and the affidavit itself if baxter has concerns did your image was going to fall and again this is why we have computer experts to do this i am not a computer expert i don't profess to be but it is basically