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>If they objection is to the technology: Lots of companies use special techniques to avoid creating a paper trail. It's called "phone calls"

I had a friend who worked at a nonprofit who always knew when the general counsel wanted to discuss something sensitive - because he'd call on your office phone. (I suspect he thought it was harder to record a phone call than a 1:1 convo)

What's funny is he didn't realize that the mere chain of calls contained metadata. For example, if the first workday after a boozy company party the HR rep in charge of the interns gets a call, then an intern, then the intern goes into HR, then a senior staffer gets a call, then the senior staffer goes in to speak with HR... certain inferences can be drawn.



Ya, but only inferences. Anyways, it’s much harder for discovery than a complete conversation.


Once you put everyone under oath, unless everyone agrees to the same story, it's not too difficult to make the truth come out.




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