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custodian of records. A person or institution that has charge or custody of records.

                   damages. Money claimed by, or ordered to be paid to, a person as compensation for loss or injury.

                   database. An application that provides the tools for data retrieval, modification, deletion, and inser-
                       tion (for instance, Access, MySQL, and Oracle). Such applications also can create a database and
                       produce reports.


                   data culling. The umbrella term used to describe the technical tactics or processes employed to re-
                       duce a large document population to a much smaller set.  fn 25


                   data custodian. See custodian.

                   data field. In databases, a space reserved for a specified piece of information in a data record. In a
                       table-oriented database management program, in which all retrieval operations produce a table
                       with rows and columns, data fields are displayed as vertical columns.

                   data manipulation. In databases, the use of the basic database manipulation operations, such as data
                       deletion, data insertion, data modification, and data retrieval, to make changes to data records.


                   data mining. In a data warehouse, a discovery method applied to very large collections of data. In
                       contract to traditional database queries, which phrase search questions using a query language
                       (such as SQL), data mining proceeds by classifying and clustering data, often from a variety of
                       different and even mutually incompatible databases and then looking for association.

                   Daubert hearing. A hearing conducted by federal district courts, usually before the trial, to deter-
                       mine whether proposed expert testimony meets the federal requirements for relevance and relia-
                       bility. See Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579, 113 S.Ct. 2786 (1993).


                   declarations. A formal statement, proclamation, or announcement.

                   defendant. A person sued in a civil proceeding.

                   demurrer. A pleading stating that although the facts alleged in a complaint may be true, they are in-
                       sufficient for the plaintiff to state a claim for relief and for the defendant to frame an answer.

                   deposition. A witness’s out-of-court testimony that is reduced to writing (usually by a court report-
                       er) for later use in court or for discovery purposes.

                   de duplication. The process of identifying and segregating those files that are exact duplicates of
                       one another. The goal is to provide a deliverable that contains one coy of each original document
                       while maintaining the information associated with each instance of that document with the col-
                       lection.  fn 26





        fn 25   Ibid.

        fn 26   Ibid.



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