Executive Summary
Legal document reviews in high stakes cases are today characterized by the significant amount of information created and stored electronically. An effective document review is an investigative process that provides counsel with real time insight into the nature of the dispute as it evolved, including the rich perspective of each participant during its evolution. Electronically Stored
Information (ESI) and large scale document reviews are handled better by law firms that are steeped in a culture of curiosity and the importance of fact based arguments. The volume of electronic discovery dictates that an investigatory approach utilizing appropriate search technology is required during document review and analysis. An attorney on the trial team should provide sufficient insight into the themes, concepts and narrative of the dispute to enable the document review team to engage in the successful subject coding, or “tagging” of the documents. In order to guide the search effectively, it is essential that the attorney representing the trial team be prepared to respond to questions from the document review team in a timely fashion. It is also essential that the document review and analysis be approached as an investigation, where as relevant information is uncovered, it is utilized to adjust case related themes and concepts to provide the best legal representation. The investigation of the discovery materials must remain proportional to the significance of what is at stake.

Two Introductory Case Studies:...................................................................................................... 1
U.S. v. Swanson, a criminal anti-trust case ................................................................................. 1
A global law firm BK investigation, and 26 issue tags ............................................................... 1
Assumptions .................................................................................................................................... 3
Roles and Responsibilities .............................................................................................................. 3
Investigatory Document Review and Analysis in Three Concurrent Tiers .................................... 5
Investigatory vs. Linear Document Review................................................................................ 6
The use of Search and Sampling during Document Review ...................................................... 7
Statistical Sampling .................................................................................................................... 7
Quality Control Protocol during Managed Document Review ................................................... 7
APPENDIX A ............................................................................................................................... 13
The use of search to drive the review of “standard” files ......................................................... 13
Dealing with “exceptions” in processing .................................................................................. 13
The Specific Challenge of Tagging for Relevance .................................................................. 14
The Specific Challenge of Tagging for Privilege ..................................................................... 15
The Specific Challenge of Locating and Identifying “HOT” Documents ............................... 15
APPENDIX B ............................................................................................................................... 16
Document Review Security: ..................................................................................................... 16
Security at BartkoZankel‟s offshore review facility: ................................................................ 16
APPENDIX C ............................................................................................................................... 18
Hosting for document review and production: ......................................................................... 18
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U.S. v. Swanson, a criminal anti-trust case
The first document review for which we included an offshore component was U.S. v. Swanson, a criminal anti-trust trial stemming from the investigation of the DRAM industry. Discovery was characterized by the Department of Justices‟ producing voluminous Grand Jury materials that were poorly/non-indexed, and laden with garbage (files with non-usable information, code files in a non-code related event, et al.). In addition the Grand Jury materials included the substantive discovery that had already been done in related civil cases involving the DRAM industry.
This was a time sensitive review, and under the circumstances (the indictment of an individual), we felt it was important to both achieve the highest quality review in the available time frame and keep the costs for that review as reasonable as possible for Hynix, the company that was covering the defense expenses.
The time constraints caused us to have to carve up the Grand Jury production and further civil productions and to actively choose which portions to review. The „carving‟ was driven by active searches in consultation with the trial team, and the final decisions about which portions to exclude from inclusion in the „eyeball‟ component of the document review were made by informed lead counsel.
The jury voted 10-2 for acquittal and the government dismissed the case.
A global law firm BK investigation, and 26 issue tags
During the initial investigative and discovery phase of the bankruptcy of a 119 year old global law firm, it was determined that one of the greatest difficulties was going to be sorting out what was worth looking at within the dilapidated IT infrastructure of a 119 year old law firm with thousands of clients.
We relied on our use of a front end SQL database for the sorting of “standard” versus
“exception” files and further culling through the use of natural expression searches to determine which parts of the collection to move further along into Relativity for document review. It should be noted that the original collection for the Heller Ehrman BK required that it be far more extensive than the components of it that would be initially investigated. In order for the Trustee to proceed with the pursuit of assets, the initial investigation had to yield recoveries that would fund further investigation because of limited resources.
The number of different relevant search terms and associated concepts resulted in the use of 26 issue tags during the review. Because as the number of issue tags grow, the opportunities for erroneous tagging grow as well, we were somewhat reluctant to go that high. Nevertheless, our
1 st
tier in the Philippines performed admirably. During the review, feedback and commentary from the 1 st
tier in the Philippines became the basis for inquiry into, and discovery of, a series of codenames (the names of baseball teams in the email of a law firm that had never represented any) used to describe various efforts to merge or sell the firm before its demise. While there was an awareness of codenames, the problem was figuring out all of the codenames in use, and when
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they changed. In the case of three potential Chicago suitors, there were the Cubs and the White
Sox, but having run out of baseball teams, there was also Deep Dish Pizza which was also rendered on occasion as: DDP, or sometimes just Pizza. Determining which emails were relevant was a significant project, as they had to be produced to the Bank of America. One of the challenges was to generate searches that reduced the number of false positives through the use of time frames and the careful comparison of search outcomes. And while the firm had an official email deletion policy, it was dysfunctional, as a single individual had been tasked with the review of email marked for deletion and was simply overwhelmed. We have had several conversations with purveyors of various predictive coding solutions who believe that their own tools would not have been able to identify these codenames. (It should be noted that we are in the habit of applying our own “predictive” efforts across individual queries when they are large enough and we believe our search methodologies will be helpful. We do not in any way dismiss the potential benefits of predictive coding, but we believe that it is very important to understand its limitations.)
This initial investigatory phase of the Heller Ehrman BK has already resulted in an $8 million settlement between the Bank of America and the Heller Ehrman Estate.
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This paper discusses measures that have been effectively used by BartkoZankel‟s practice support group--BZresources--during investigatory document review and analysis for civil and criminal anti-trust trials, a nine figure confidential arbitration, and the investigatory phase of a global law firm bankruptcy.
This paper assumes that adequate measures and the documentation of chain of custody were undertaken during the collection, culling, and processing stages of any case related ESI. Please note that nothing as straightforward as deNisting, de-duplication versus near de-duplication, or the batching of “trash” email (law.com, listservs, other clearly not relevant group mailings) has been covered here.
It is assumed that the collected ESI will be hosted in a secure location with adequate fail safes, redundancy and back ups in the case of power and network outages, and that an appropriate document review “tool‟ will be chosen to facilitate the document review and analysis.
Organizational technology to facilitate document review and analysis is in a constant state of development, and we often write our own scripts to improve workflow or to enhance Quality
Control and Reporting. Please see Appendix B for commentary on Security.
Being “technology agnostic” does not prevent us from understanding and advising on the potential benefits of Enterprise level tools in the early limitation of ESI productions to outside counsel.
BZresources has been engaged directly by other law firms on behalf of their clients, and BZr is open to direct engagement by companies.
Investigatory document review and analysis requires that the client, trial team, and Project
Manager frame the overall scope of the investigation that will govern the document review. A stable representative of the trial team‟s involvement and supervision is sufficient for most litigation.
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Information must be exchanged to ascertain the scope of a project
We believe that the representative from the trial team should remain constant throughout the event, as experience has shown us that shifting this responsibility amongst members of a team creates unnecessary confusion. The goal is stable points of contact and a clear path for the exchange of information and direction throughout the course of the engagement.
The Project Manager is responsible for:

Advice during the determination of the scope of the document review and analysis

Providing a constant and stable point of contact

Reporting at agreed upon intervals to counsel
Counsel is responsible for:

Supplying and updating the case narrative
 Responding to questions and concerns from the Project Manager
 Providing and adjusting topics for investigation as “Hot” documents are returned
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Culled
Custodian ESI
Counsel
Project Manager
Relevant materials for Production
The investigation and production of relevant materials
BZresources utilizes a Three Tier Document Review and Analysis framework, where the 1 st tier is comprised of attorneys and legal professionals in the Philippines who can be relied upon to provide greater attention to detail and to carefully follow instructions. The 2 nd
tier at our SF
Offices is comprised of attorneys able to make contextual decisions regarding potential relevance, and to identify the more significant “hot” documents. The 3 rd
tier consists of a Final
Privilege and Quality Control Team, which reviews for privilege, reasons for privilege, finalizes the privilege and redaction logs, and addresses any remaining outstanding decisions related to the document review and analysis. All 3 Review Tiers are managed by BartkoZankel eDiscovery
Counsel.
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1st tier review ‐ issue coding, potentially privileged, further review, first cut of
“hot” docs
2nd tier review ‐ enhanced issue coding, deposition preparation, document and issue research
Privilege review ‐ advanced privilege analysis and preparation of privilege log under direct supervision of responsible counsel
Redaction and redaction log
Investigatory Document Review and Analysis in Three Concurrent Tiers
Utilizing offshore review services allows us flexibility with staffing, enabling us to quickly expand to meet short deadlines during high volume relevance reviews. Review Management is provided by Document Review Project Managers supervised by BartkoZankel litigators. The depth of Document Reviewer Training and selection of Quality Control criteria are made in conjunction with the client‟s representative, ensuring the greatest accuracy, delivered on time and within the agreed upon budget.
Investigatory vs. Linear Document Review
BartkoZankel moved to an investigatory rather than linear engagement with discovery materials in 2005. The size of discovery collections has increasingly become such, that a linear approach is time consumptive and unsophisticated in light of the opportunity to conduct searches across
Electronically Stored Information (ESI). It was determined that an interactive engagement with the discovery materials, where the narrative was expanded or collapsed based upon review findings was far more useful and efficient than a linear engagement.
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The opportunity to collate supporting materials and test potential theories for support inside the discovery materials has also helped generate a deeper and more facile understanding of the discovery materials amongst our own attorneys, and those of outside firms who have engaged our services.
The use of Search and Sampling during Document Review
The Trial Team should direct the conferences focused on early interviews accompanied by selected peeks at the related Electronically Stored Information (ESI). The Trial Team should be involved during the initial generation of keywords, a cast of characters, the beginnings of a timeline, and the identification of facts that must be checked in regards to the case narratives.
While the use of keyword search to help identify responsive documents has swiftly become a standard culling practice, BZr has further experience in the use of regular expression searches,
SQL search, the use of Concept and Content Search Engines, and email threading tools. Early theories and concepts of the Trial Team must be tested and refined against the actual discovery materials using such search tools, and analysis of the document sets returned, or a statistical sampling of those document sets depending upon their size. Other tools for Technology Assisted
Review, such as “predictive coding”, can also be used in this context, where the “predictive tool” is applied across a document set that is returned. BZr has run in-house tests on the functionality of 4 “name brand” providers in this space. Our use of “concept search” in previous reviews could be replaced by “predictive coding” during a real world review. In either circumstance, the lead attorney remains the appropriate driver of initial themes and concepts that inform the identification of issues that should be tagged during the subjective coding of the case related ESI.
Please see Appendix A for further information on the use of search to drive document review.
Statistical Sampling
Statistical sampling can be used to develop a principled and structured way to discuss the entire document population, or any given sub-set of the population. Testimony regarding the use of sampling during discovery has been offered in several court cases. BZr recommends the sampling of excluded documents (non-responsive set), and on occasion the sampling of larger sub-sets returned during individual searches to determine whether particular sub-sets identified by query should receive further review.
Quality Control Protocol during Investigatory Document Review
An investigatory approach to document review structured in 3 tiers including a final review for privilege requires the significant involvement of counsel via a Project Manager who maintains a global perspective as the document review unfolds. The attorneys who interact with the Project
Manager must be thoroughly briefed on the significance of the matter and able to provide thoughtful judgment on the significance of “hot” documents in dialogue with the Project
Manager, while helping suggest searches to populate individual reviewers document queues based on investigative priorities set by the trial team.
A member of the Trial Team should act as liaison between the document review team, the
Project Manager (PM), and trial counsel. If the trial team does not provide adequate supervision,
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the document review will inevitably suffer. Substantive questions from the document review team should ideally receive a response within 12 hours in order to keep the process flowing smoothly.
1) Thoughtful involvement and active supervision by well informed counsel is the most general and essential of several steps required to perform sufficient QC during a high volume document review.
After being appropriately briefed by counsel, the Project Manager must „train‟ the review team for the specific document review in which they will be involved. The more informed, monitored, and supervised, a large group of reviewers is, the more thoughtful and correct will be the document review and subjective issue coding. The training, and any subsequent updates to it that may be required as the discovery collection yields new, important information to supervising counsel, provides the document reviewers with insight into counsel‟s developing themes, and allows the thoughtful coding of documents that are both supportive and damaging to that strategy, as both must be identified.
The review team must have a general understanding of the litigation before the review begins.
This can be accomplished by an appropriately informed member of the Trial Team in 1 to 2 hours.
2) Sufficient reviewer training prior to the review, and training updates during the review as required.
The first tier of the document review should begin on a “double-blind” basis. That is, at the very outset of the review, pairs of document reviewers should be receiving the same review queues of documents (identical queues). By beginning the review in this fashion, analysts can compare coding on a 1 to 1 basis, while checking discrepancies and identifying any reviewers who may have misinterpreted the initial training. If this begins smoothly, we have confirmation that the training was well received, and if it is rocky, it points out issues that need to be clarified early on before any bad habits have developed.
When tagging for relevance, privilege, and “hot” documents, appropriate instruction is a key element of success. A poorly trained reviewer will tag poorly. A well instructed reviewer may misunderstand a concept and tag certain items inappropriately, but this can be identified and corrected early if the review begins as a double-blind event with proper Quality Control (QC) protocols. Please see Appendix A for further discussion of the specific challenges of accurate tagging.
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A “double blind” start is short in comparison to the duration of the actual review, but is an important way to cautiously begin such a significant undertaking. Given the degree of importance associated with any given query that is later batched to be queued for a specific reviewer, it may be appropriate to QC their initial progress via double blind review later in the document review as well. Because of budgetary constraints, double blind review is never a significant portion of a document review; however, we believe it should be used judiciously to ensure quality at the front end.
3) Appropriate use of “double-blind” review to identify how well individual reviewers have integrated the review training into their subjective issue coding decisions.
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Supervision of the review should also entail the use of a review team leader drawn from the review team, engaged in an active QC role throughout the review, and facilitating the transfer of information amongst the team. The team leader is largely responsible for answering reviewer questions, overseeing the exchange of information amongst the review team as the document review unfolds, and interacting with the PM for further clarification on the subjective issue coding of documents as required. The team leader is also involved in providing QC by sampling the queues of the other members of the team. Reviewers may at times be pulled aside to provide
QC to the queues of other reviewers on the team as caution and budget dictate. Any discrepancies in coding judgment should be identified and sent up the supervisory chain for final decision on the appropriate coding. The team leader makes sure that the decision log being kept in conjunction with the PM is posted for review team reference.
4) The designation of a review team leader drawn from the review team to facilitate information transfer inside the review team and act as a point of contact for external supervision.
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During a “concurrent review”, responsive documents are moving from the First into the Second tier for a second review and coding qualification, along with further appraisal of any associated issue tags (during the investigatory review of the global law firm bankruptcy, there were 26 issue tags), or the confirmation of the designation: “potentially privileged”. We utilize a Second Tier comprised of litigation associates and experienced contract reviewers, who have access to the
Document Review Project Manager in charge of the document review and controlling the population of individual document review queues. The Trial Team remains in contact and communicates with the Document Review Project Manager and Second Tier document review team as it deems appropriate.
B001
Final privilege review is driven by search and accurate training on “privilege” and “attorney work product” for any given legal event, and the use of “further review” tags for documents that needed further appraisal by more senior counsel. The tag “potentially privileged” is available throughout the review. Such documents are re-batched with documents identified by search and query for privilege review.
5) Three tier concurrent review, where the first tier moves forward to the second and the
Privilege review is driven as a separate event.
Many of our processes have been adopted as “best-practices” by other law firms that have interacted with BZresources/BartkoZankel.
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Over the last 7 years, BZr has undertaken document reviews on behalf of BartkoZankel and other law firms and has performed on time and under budget in all of them. The more significant of these reviews have made use of our facility in the Philippines. BZr has supervised each stage of the eDiscovery process, from collection through review in all of these events, and
BZresources/BartkoZankel has never been subject to sanctions of any kind in regard to eDiscovery.
While BZr has great faith in the quality of our Investigatory Document Review, advising our clients in the negotiation of appropriate “clawback” agreements with the opposing side is a prerequisite to the work we do, as the sheer volume associated with discovery today precludes 100% accuracy in production.
BZr firmly believes that an active and involved representative of the trial team is a pre-requisite to effective document review and analysis.
BZr does not believe it is desirable for the trial team representative to rotate, as this interjects an uncertainly effect into responses to questions from the document review team.
BZr is certain that document review teams must be adequately instructed to enable success.
BZr is certain that a precise decision log must be maintained and kept available to the review team throughout the document review.
BZr attributes its success during investigatory document review and analysis to maintaining a close and stable liaison relationship between client, counsel, and the PM of the document review; the generation and regular maintenance of the document review decision, redaction and privilege logs; and the prompt resolution of questions from the document review team.
BZresources has been providing effective trial tested management of eDiscovery and investigatory high volume document reviews since 2005, and we would be happy to write a formal proposal for any specific event.
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The use of search to drive the review of “standard” files
The exclusion of non-relevant documents through search is integral to achieving accurate tagging. This is where the reasonable fear that something relevant will be excluded and not reviewed is generated. We exclude with caution, and in consultation with the Trial Team. We rely on the Trial Team to direct the proportionality of the event, as a higher level of caution is equivalent to greater expense.
Certain actions can be applied across all reviews, but it must be remembered that all reviews are unique investigatory hunting expeditions. Targeted searches across the total document pool must be used to folder and batch queries for distribution to the queues of individual reviewers.
We separate “standard” and “exception” files, “exception” files are foldered and set aside as they require more complex processing (see next section for “exception”). We initially process only the standard email and efiles. Inside the Relativity database, we then run our initial key word searches as we are sure that each document is 100% searchable. We batch and folder the resulting documents, run an index of the words in the documents contained in each folder and then provide counsel a list of key words "by rank". We use data analysts familiar with regular expression searches to speed this process.
Searches of the top 5 key words (by rank) in each folder become "mini-reviews", and if the results are responsive to the production order, become key word recommendations to counsel.
The Trial Team is thus equipped to negotiate keyword search terms with opposing counsel based on a preferred list that is the outcome of the iterative occurrence of words in the database modified by counsel‟s own subjective understanding of the case and its issues. Counsel queries regarding potential relevant keywords are run across the database as requested.
Cursory relevance and privilege are driven by search. The search terms developed in conjunction with the trial team are first run against the standard files, folders generated out of these queries are then batched to be loaded into individual reviewer queues for visual review, coding of issue tags, and confirmation of relevance, privilege, and the identification of “hot” documents.
Dealing with “exceptions” in processing
Because “e‟processing” struggles with:
Password protected files
PDFs that have not been OCR‟d
JPEG, TIFF with no text
Excel (tabs cannot be text searched)
PPT files (headers and footers of PPT in various versions are not text searchable—i.e., if
“attorney client privilege”, or “confidential” were to be in the header or footer of many
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versions, they could only be identified by a human reviewer looking at them, as a text search would miss the image “confidential” et al.)
"Exception" files are files, where standard e'processing tools cannot extract searchable metadata and/or searchable text. We treat these “exception” files differently than the “standard”, easily processed ESI (PST files, Word, etc.) which travel a simpler route to becoming fully searchable.
"Exception" documents which have been separately foldered take longer and are more expensive to process. Password protected files will require special software to crack the password. We perform visual reviews of every PPT in the collection (a slow and costly process, but one which ensures that privileged documents are not produced—managing costs of this nature is one of the reasons we developed our facility in the Philippines) as the text is not searchable. We have also found ourselves thankful to have visually reviewed the page tabs in Excel spreadsheets, as it is not possible to text search Excel page tabs, and we know from experience that they can be titled with names on the privilege list.
Our productions are by custodian and based on the ratio of exception to standard files (i.e., so that a CD or DVD of nothing but exceptions does not arrive and raise red flags just by being what it is—looking like an exception).
We always urge the Trial Team to negotiate the production of “exceptions” with the other side.
This can prove more or less fruitful depending on the significance of the event, but in instances where “exceptions” can be shown to be largely inconsequential through sampling and production in native, it can be a significant cost control.
1) Process only the standard email and efiles and "folder" exception files.
2) Run initial key word searches across the "standard" email and efiles that are now 100% searchable.
3) Batch and folder the resulting documents, run an index of all the words in the documents contained in the folders, and provide a list of key words "by rank".
4) Run searches of the top 5 key words by rank, and perform "mini-reviews". If the results are responsive to the production order, make those key word recommendations to counsel. (This variable can be expanded, although the larger it becomes, the less significant the impact for sorting.)
5)
“Exception" documents take longer and are more expensive to process. Password protected files oftentimes require special software to crack the password and depending on the litigation, we will perform manual reviews on every PPT in the collection, as well as Excel page tabs (slow and costly, but ensures that privileged documents are not produced).
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1) Keyword searches of privilege names across database.
2) Foldering and manually reviewing "exception" documents.
3) Using software that will provide us a dictionary of words in sub-setted documents. Our standard is to identify the top 5 key words contained in documents that were tagged for privilege and have our Privilege Reviewers manually review them.
4) The use of Philippine reviewers to perform many of these „visual‟ tasks enables our data analysts to perform dynamic searches and promote those outcomes to the queues of reviewers specializing in Privilege (or Issues), while remaining within the review budget.
5) We use a final Privilege review team to finalize privilege tags and generate the privilege log. This allows us to pay attention to the issue of contextual privilege.
1) The use of a concurrent review where examples of potentially “hot” documents selected by the trial team are provided during reviewer instruction, and are refined through a positive feedback loop during the ongoing review.
2) Adequate training of the review team, along with training updates as the review is refined.
3) As “hot” issues are defined, targeted searches across the entire database to create more refined queues.
4) As “hot” documents are tagged and forwarded to the trial team, searches are made based on the trial teams thoughts about the document they have just seen, and any potentially related ones they may hope to find.
5) Periodic collaborative meetings involving the Project Manager and a key member of the
Trial Team are extremely useful in refining this process as the overall trial themes evolve.
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Document Review Security:
BartkoZankel has effectively used a variety of security protocols during eDiscovery. Security, particularly electronic security, is an active and changing field where appropriate measures must be taken in relation to actual and perceived risk. Appropriate security measures are the outcome of full and informed discussions between the firm and its clients in regard to known or potential threats.
Transfers of ESI to the firm and from the firm to hosting facilities are logged, and transfers made on CD/DVD, hard drives, and by FTP transfer are encrypted. All CD/DVD, hard drives, thumb drives, and other media are stored in a locked facility accessible only by authorized personnel.
Staff in the law firm sign project related confidentiality agreements beyond their standard employee confidentiality agreement.
Security at BartkoZankel‟s offshore review facility:
1) The Philippine Center for Population Development (PCPD) compound: The entrance to the compound is staffed by a sentry enforcing a no sticker- no entry policy. Those without the
PCPD sticker on their vehicles are required to leave their driver's license. There is a security desk in the lobby of the building where visitors are required to leave their identification cards and are issued a visitor's pass before entering the building. The compound is also staffed by roving guards.
2) Main entrance to Philippine Interactive Audiotext Services, Inc. (PIASI): This is staffed by a guard who signs in all entrants to PIASI (employees, visitors, etc). For Document Review
Projects, a log sheet is prepared before the project begins. The log sheet is a list of each reviewer assigned to each particular Review project and the shift to which he/she is assigned.
Upon entry, each reviewer registers attendance by signing alongside his/her pre-typed name on the log sheet. The guard indicates time of arrival based on a clearly visible clock hanging beside the security area. This procedure is a manual check that applies to all reviewers on a daily basis.
3) Review Facility Entrance: There is a door access system in place. Only designated personnel have access to this area. The system is able to identify those who enter the facility as well as the time they enter. For Document Review Projects, a passkey system allowing only preregistered reviewers/managers to enter and have access to specific areas can be activated, augmenting the standard door access system.
4) The Review Area: The current review area is an enclosed and separate space within the PCPD building with its own doorway entrance and hallway passage. The dedicated and secure space can be expanded as required.
5) Cellphones and Bags: There is a locker cabinet in the hallway passage outside the Review
Room that serves as a depository for cell phones, bags, etc of those who enter the facility. As
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added security, GSM/CP signal jammers are in place in the facility and can be activated should this be desired.
6) Closed Circuit Television in the Review Area: Cameras are focused on strategic areas --- in the main entrance where the door access system is located, in the passage hallway where the locker cabinet is located and inside the Review Room where the reviewers are stationed. The
CCTV has a recorder and is motion-activated. Currently, the CCTV recordings are stored for one week. This can be adjusted subject to client request and company operational policies. A regularly scheduled security review of the CCTV can be established as a standard policy specific to any Review related activities.
7) Desktop Security Measures: Should the client require a policy that will automatically lock the user‟s desktop at a specific time interval, such a policy can be activated. In addition, an audit trail can be established in the Active Directory Services of the domain. However, it is important to determine the extent of auditing, as the extent can affect other PC based resources.
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Hosting for document review and production:
In the matters mentioned in the case studies, processing, culling, and hosting for review was done per our instructions by LDiscovery on their secure network which services law firms, corporations, and government contracts. Relativity with Equivio plug-ins for email threading and de-duplication was chosen as the document review software or “tool”. Equivio has recently come out with a “predictive coding” plug in for Relativity that was not available at the time of any of the matters previously mentioned.
There are several vendors who maintain ISO certification for their hosting facilities.
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