February] 0,2009

Ms. Debbi Bumpous

Chief Information Officer
Northern State University
1200 South Jay Street
Aberdeen, SD 57401
northern j?/i;t;tf university
PRIVILEGED AND CONFIDENTIAL:
ATTORNEY WORK PRODUCT AND ATTORNEY ICLIENT COMMUNICATION
Re: Darley Intemational, LLC v. South Dakota Intemational Business Institute;
Hanul Professional Law Corporation
Dear Ms. Bumpous:
As a formal follow-up to my conversations and e-mails with you regarding the preservation of
SDIBI records, this letter and those communications constitute a legal hold directed to you,
SDIBI and its employees. You are further instructed to not share or otherwise provide copies of
this letter with anyone other than your staff who may have preservation duties hereunder. The
same instructions apply to them. This letter defines the scope of preservation actions occurring
within the broad definitions we have previously discussed.
It is a matter of utmost importance that your offices preserve and prevent alteration of all
electronic information related to the South Dakota International Busines5 Institute_ South Dakota
Regional Center, Inc., .loop Bollen, Darley International, LLC, Robert B. Stratmore, Hanul
Professional Law Corporation, recruitment of overseas investors for EB-5 inveslor visas projects,
economic development activities directed towards Far Eastern countries, and prospective
investors f'Or dairy, tilapia, and meat packing projects, from at least January 1,2000, to the
present. This includes all send and receive e-mails from all third parties and State agencies and
includes all internal electronic documents, data, and document drafts and related attachments.
"Documents and data" as used here means not only electronic documents, but also any audio
recordings, video tapes, e-mail, instant messages, word processing documents, spreadsheets,
databases, calendars, telephone logs, contact manager information, internet usage files, and all
other electronic information maintained, created, received, andlor stored by SDlBI or its
employees on computer systems. This obligation includes "documents and data" on or in all
sources, including electronic tiles, computer hard drives, removable media, such as CD's and
DVD's, laptop computers, PDA's, Blackberry devices, and any other locations where printable
University Counsel, 1200 South Jay Street, Aberdeen. South Dakota 57401-7198, (605) 626-2379, Fax (605) 626-2666
Exhibit 1
Shekleton 0001
February] 0,2009
Ms. Debbi Bumpous
Chief Information Officer
Northern State University
1200 South Jay Street
Aberdeen, SD 57401
northern j?/i;t;tf university
PRIVILEGED AND CONFIDENTIAL:
ATTORNEY WORK PRODUCT AND ATTORNEY ICLIENT COMMUNICATION
Re: Darley Intemational, LLC v. South Dakota Intemational Business Institute;
Hanul Professional Law Corporation
Dear Ms. Bumpous:
As a formal follow-up to my conversations and e-mails with you regarding the preservation of
SDIBI records, this letter and those communications constitute a legal hold directed to you,
SDIBI and its employees. You are further instructed to not share or otherwise provide copies of
this letter with anyone other than your staff who may have preservation duties hereunder. The
same instructions apply to them. This letter defines the scope of preservation actions occurring
within the broad definitions we have previously discussed.
It is a matter of utmost importance that your offices preserve and prevent alteration of all
electronic information related to the South Dakota International Busines5 Institute_ South Dakota
Regional Center, Inc., .loop Bollen, Darley International, LLC, Robert B. Stratmore, Hanul
Professional Law Corporation, recruitment of overseas investors for EB-5 inveslor visas projects,
economic development activities directed towards Far Eastern countries, and prospective
investors f'Or dairy, tilapia, and meat packing projects, from at least January 1,2000, to the
present. This includes all send and receive e-mails from all third parties and State agencies and
includes all internal electronic documents, data, and document drafts and related attachments.
"Documents and data" as used here means not only electronic documents, but also any audio
recordings, video tapes, e-mail, instant messages, word processing documents, spreadsheets,
databases, calendars, telephone logs, contact manager information, internet usage files, and all
other electronic information maintained, created, received, andlor stored by SDlBI or its
employees on computer systems. This obligation includes "documents and data" on or in all
sources, including electronic tiles, computer hard drives, removable media, such as CD's and
DVD's, laptop computers, PDA's, Blackberry devices, and any other locations where printable
University Counsel, 1200 South Jay Street, Aberdeen. South Dakota 57401-7198, (605) 626-2379, Fax (605) 626-2666
Exhibit 1
Case 4:14-mc-00118-KES Document 14-1 Filed 10/20/14 Page 1 of 2 PageID #: 90
Page 2
and electronic data is stored. Keep in mind that any of the above-mentioned sources of relevant
information may include personal computers SDIBI or its employees use at home or at other
locations.
[n order to comply with its legal obligations, NSU must immediately preserve all existing
documents and data relevant to the action described above, and suspend deletion and destruction
of relevant "documents and data" through its own activities and through Records Management.
Additionally, NSU must take care to prevent overwrite or destruction of any data, e-mail or other
documents concerning the relevant issues that are in electronic files or stored on SDIBI's
employee's desk or personal computers, servers, etc. so that all of the records that exist under this
hold regarding these matters will be preserved.
Electronically stored data is an important and irreplaceable source of discovery and/or evidence
in this matter. NSU must take every reasonable step to preserve this information until further
notice from me or our attorneys. Failure to do so could result in the imposition of monetary
penalties. Please call me if you have any questions.
This "hold" on destruction should remain in place until I tell you otherwise, generally upon
completion of the legal proceedings concerning this matter.
Shekleton 0002
Page 2
and electronic data is stored. Keep in mind that any of the above-mentioned sources of relevant
information may include personal computers SDIBI or its employees use at home or at other
locations.
[n order to comply with its legal obligations, NSU must immediately preserve all existing
documents and data relevant to the action described above, and suspend deletion and destruction
of relevant "documents and data" through its own activities and through Records Management.
Additionally, NSU must take care to prevent overwrite or destruction of any data, e-mail or other
documents concerning the relevant issues that are in electronic files or stored on SDIBI's
employee's desk or personal computers, servers, etc. so that all of the records that exist under this
hold regarding these matters will be preserved.
Electronically stored data is an important and irreplaceable source of discovery and/or evidence
in this matter. NSU must take every reasonable step to preserve this information until further
notice from me or our attorneys. Failure to do so could result in the imposition of monetary
penalties. Please call me if you have any questions.
This "hold" on destruction should remain in place until I tell you otherwise, generally upon
completion of the legal proceedings concerning this matter.
Case 4:14-mc-00118-KES Document 14-1 Filed 10/20/14 Page 2 of 2 PageID #: 91