1. One or more computer-readable storage media having computer-executable instructions embodied thereon that, when executed by a processor, cause the processor to instantiate one or more program modules that facilitate freeform selection of electronic ink using a digitizer that is connected to the processor, the one or more program modules comprising: a user interface module that collects points for a plurality of unconnected freeform selection paths, wherein each of the plurality of unconnected freeform selection paths is created in response to a user holding a user input device against the digitizer while dragging the user input device across the digitizer such that the resulting selection path touches a graphical object and displaying a simultaneous selection of each of the plurality of graphical objects based upon the freeform selection paths on a display surface wherein each of the plurality of unconnected freeform selection paths includes selection ink and the graphical objects include handwritten electronic ink strokes input via the digitizer; and an encounter selection module for simultaneously selecting each of the graphical objects responsive to the freeform selection paths touching the graphical objects; wherein the user interface module displays a graphical hollow appearance for the plurality of graphical objects responsive to selection of the plurality of graphical objects by the encounter selection module, the graphical hollow appearance comprising a perimeter of the handwritten ink strokes having a dark contrast with respect to an interior of the strokes bounded by the perimeter.