Electronic records and data that are stored on a computer are subject to a claim of conversion under New York law. Thyroff v. Nationwide Mutual Insurance Co., No. 41, 2007 N.Y. LEXIS 264 (N.Y. Mar. 22, 2007).
The typed signature of a judge, which appeared in the "/s/ Name" format on electronically filed judgments, satisfied the "signed and in writing" requirement of Arizona Rule of Civil Procedure 58(a). Haywood Securities, Inc. v. Erlich, No. CV-06-0280-SA, 2007 Ariz. LEXIS 1 (Ariz. Jan. 10, 2007).
Articles from newspapers, trade journals and other periodicals that are printed from an Internet search service are not admissible under Fed. R. Evid. 902(6), which provides for self-authentication of "printed materials purporting to be newspapers or periodicals." U.S. v. Premera Blue Cross, No. C01-0476P, 2006 U.S. Dist. LEXIS 70933 (W.D. Wash. Sep. 29, 2006).
The affixation of an electronic signature to a deposition supporting an e-ticket before the entry of information particular to the charge is entered, does not violate the New York statutory requirements for the execution of such documents. People v. Corletta, No. 1E21016CSP, 2006 N.Y. Misc. LEXIS 842 (New York Justice Court, Town of Webster, Monroe Cty Apr., 18, 2006).
An e-mail message sent by a plaintiff's attorney requesting a modification of a settlement agreement was not a "subscribed" writing as required by the Michigan Court Rules applicable to agreements between parties to litigation, because the attorney's name was not typed or appended to the end of the message and appeared only in the heading of the message. Kloian v. Domino's Pizza, L.L.C., No. 263882, 2006 Mich. App. LEXIS 3796 (Mich. Ct. App. Dec. 28, 2006).
The three-day extension of filing deadlines under the "mailbox rule," applicable to responses to papers served via first class mail under Federal R. Civ. P. 6(e), also applies to responses to papers served electronically. Nowak v. Ford Motor Co., No. 06-11718, 2006 U.S. Dist. LEXIS 92780 (E.D. Mich. Dec. 22, 2006).
The Tennessee Public Records Act does not require a custodian of public records to provide such records to a citizen in the manner that the citizen requests. Wells v. Wharton, No. W2005-00695-COA-R3-CV, 2005 Tenn. App. LEXIS 762 (Tenn. Ct. App. Dec. 7, 2005).
According to the press release, the department has entered into agreements with the Southern Governors’ Association, to host the Gulf Coast Health Information Task Force, which will bring together local and national resources and coordinate the planning for a digital health information recovery; and the State of Louisiana Department of Health and Hospitals, to develop a prototype of health information sharing and electronic health record (EHR) support that can be replicated throughout the region.
Press Release: http://www.hhs.gov/news/press/2005pres/20051117.html
An Illinois county is not precluded by the state freedom of information law from charging a fee for access to electronic copies of public land records by Internet FTP protocol, even if the fee exceeds the county's cost of providing access. First American Real Estate Solutions, L.P. v. Moore, No. 05 C 2300 (N.D. Ill. Sep. 13, 2005). The court granted summary judgment dismissing a commercial information provider's claim under the Illinois Freedom of Information Act. The court noted that while a provision of the Illinois FOIA precludes charges in excess of the county's actual costs, another subsection of the same provision permits charges in excess of actual costs if authorized by another state statute. The court found that the state statute relied upon by the county permits charges of more than $.50 per document, the amount charged by the county for FTP access to the documents.
