Digital White Papers

75 WWW.ILTANET.ORG | ILTA WHITE PAPER LITIGATION AND PRACTICE SUPPORT Managing Incoming Document Productions Strategically from a document-by-document review. If you have negotiated search terms, try running them through the production to see which terms resulted in responsive documents. You can use date graphing tools to look at the date distribution of the production. Create a subset of references to your client's product and chart key personnel and dates. Use dashboards, analytics and business intelligence tools to display metrics such as number of documents produced per custodian or authored by witness. You can look at email senders or recipients and graph those against custodians to identify if certain likely custodians were neglected. Analyze sent mail vs received mail, foldered vs unfoldered. You might set up predictive coding or continuous active learning to review a random sample and use the results to identify "good" documents for your side. Use your experience collecting and producing ediscovery to investigate how the other side conducted their collection and review: what can you glean from the folder path and file name information? Oen you can tell when documents were collected, whether the parties used forensics soware, what email systems they used, etc. Do you see links in the documents that go to paths that are not in the file path field? Your aorneys may want to request those documents. Anticipate the information your case team will need as the maer progresses. Lawyers love to have counts to put in briefs: how many documents did the other side redact? How many documents were produced aer the close of discovery? How many boxes would this be if we printed it all out? What will you need for deposition and trial? Is your database set up for fast printing of potential exhibits? Are there certain documents that people ask for repeatedly, and if so, should you adjust the format of those to make them easier to work with? We know deposition exhibits oen become trial exhibits, so we oen load deposition exhibits back into our production database. It also can be useful to flag documents cited in expert reports or interrogatories. Maers do not end when your client's production goes out, and your involvement in the case does not need to end then either. Working with other parties' documents will give you more contact with your aorneys and paralegals, provide a break from the ediscovery grind, and may even give you ideas on improving your own workflow. ILTA GILLIAN GLASS An industry veteran, Gillian Glass has advised clients on all aspects of applied legal technology, electronic discovery, compliance and records retention for three decades. At Farella Braun + Martel, Ms. Glass manages paralegals, practice support, knowledge management and information governance. She supervises an in-house team of electronic discovery project managers supporting Farella's attorneys in document reviews and productions across all practice areas. Ms. Glass co-chairs Farella's Electronic Discovery Task Force, providing firmwide education on best practices and industry trends. In 2011 she received ILTA's Risk and Records Management Champion Award.

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