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As discussed here before, even after files are removed from the Windows Recycle Bin, and even after a drive is reformatted, it's still possible to recover deleted files with widely available tools. See the Tip of the Night for December 29, 2019.


Windows 10 and Windows 11 include a reset option which can help wipe the drive of your PC, overwrite the existing data with new data, but this method may not be completely effective. Under Settings if you go to System . . . Recovery, you will see an option to 'Reset this PC'.


. . .if you then choose the option to 'Remove everything', that will initiate the process of wiping the hard drive.



However, there are some reports that even after the 'Remove everything' option has been run, files can still be recovered. See this April 2023 report by Tom's Hardware, detailing the subsequent recovery of persumably wiped files with EaseUS Data Recovery.


A better, or supplementary, option may be to use a secure erase option in the BIOS firmware that manages a computer at the most basic level without the operating system. You can enter BIOS by pressing F2 when rebooting on most kinds of PC (use F10 if you have a HP computer and F1 for a Lenovo device). Or, search for 'advanced startup options' in Windows


. . . and then select the option to 'Restart now'


When your PC restarts you should then be given the option to go into Troubleshoot mode and then under advanced options select the firmware settings.



The Dell BIOS firmware includes an option to wipe the device.



 
 

A Windows operating system uses an API (application programming interface) called DirectX to allow programs installed on your PC to work with the video and audio of your computer. You can bring up the diagnostics tool for DirectX by going to Run and entering: dxdiag



The DirectX Diagnostic Tool will have tabs for each set of monitors and speakers connected to your computer. A tab named 'Render' will display information for the dedicated graphics card on your PC. It will show the VRAM for your PC - the amount of computer memory dedicated to graphics:



The very first tip of the night on April 12, 2015 warned to never try to use Trial Director or other presentation software for a courtroom electronic presentation without confirming that your laptop has sufficient VRAM. Trust me, I know from bitter experience that video clips for deposition designations with multiple segments will not play back correctly on a laptop without sufficient VRAM. The current version of Trial Director requires a graphics card with 4 GB of dedicated graphics memory. See the specs posted here.


Use the DirectX Diagnostic Tool to check how much VRAM the monitors and projectors you are connected to will require.


 
 

There's often a good occasion to set up a laptop so that Windows will stay active indefinitely and not go into screen saver or sleep mode, and lock a user's account. For example, if a laptop is being used to display the realtime feed of the reporter's transcript during a trial, it will be necessary to keep the screen on even when there are no keystrokes or mouse movements. In Windows 11, if you have already set the power management settings to prevent the laptop from entering sleep mode, or shutting down the screen:

. . . and have unselected a screen saver option:


. . . also check under Settings . . . Sign-in options :

You'll want to to prevent Windows from requiring a new sign-in after anywhere from 1 to 15 minutes.

However, it is also been my experience that if you don't have admin rights to a PC, it may be possible for a firm to force a new login even if the above-recommended settings have been selected. Check with your firm's IT department about this issue before taking receipt of a laptop to be used for realtime in court.


 
 

Sean O'Shea has more than 20 years of experience in the litigation support field with major law firms in New York and San Francisco.   He is an ACEDS Certified eDiscovery Specialist and a Relativity Certified Administrator.

The views expressed in this blog are those of the owner and do not reflect the views or opinions of the owner’s employer.

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