Special Counsel document review project managers are famous for their bag of tricks—the knowledge, tweaks, anecdotes, and experience they’ve amassed as a team from the thousands of managed reviews our national project manager (PM) Team have run for clients, both large and small. Questions clients ask are, “have you ever seen this before,” or “how have your other clients handled something like this”. Responding to these with an array of options and cost/benefit analyses is just part of a PM’s daily life.
Our 20 year history in document review has afforded us the opportunity to work with an large number of eDiscovery vendors and review platforms, and our marriage with D4 last fall has allowed us to take some of the best practices we’ve gleaned from this history and put them together in our end-to-end offering. The dynamic relationship between our document review project managers and D4’s technical litigation support PMs is consistently a hot topic. Our clients are eager to learn from the synergies we’ve been able to create and their cost saving effects downstream.
Our technical PM team shared the “hacks” they find most impactful when working with a document review project manager. They also shared how sometimes just simple tools and workarounds can create enormous efficiencies. In the discussion, the following three tips were the most popular among the team.
3 Expert Tips for eDiscovery Project Management
1. Never Underestimate the Power of Email Threading
Get the bigger picture.
One problem with traditional document review is we are often reviewing documents out of sequence and only see pieces of a conversation at any given time. It is very difficult to glean context from fragments of a conversation. This often leads to longer review as reviewers duplicate their work across several copies of the same email discussion.
Additionally, extra care has to be taken by the document review project managers to make sure that all of these documents are coded consistently because several reviewers may have different interpretations of the discussion based on missing context. Email threading helps eliminate these issues by bundling all related emails into a “family tree” of sorts that shows the original email, as well as every reply, follow-up and off-shoot of that conversation to be reviewed while being mindful of its place in the larger conversation being had. By leveraging this tool our reviewers are able to quickly track a discussion as it occurred in real time. This increases their confidence in knowing that they have all the pertinent information to make a coding decisions.
2. Use Your Review Project Manager Early & Often
Nothing Good comes to those who wait,
One common problem that we see at Special Counsel & D4 is the document review project managers join a project on the first day of substantive review, but have rarely been briefed on the issues at play and have not had a chance to go into the database and make sure it is ready for the review. We recommend to any client who is conducting a large-scale or managed review project have their Project Manager included on internal review strategy discussion as soon as practical.
This allows document review project managers to understand the issues at play. It also gives the client an opportunity to use the PM’s experience in handling these sorts of reviews. There is rarely an issue we can’t work around, but the sooner we are aware of the issue, the better. Allow your Project Manager to conduct a quick audit of review permissions, batch structure, coding layouts. This audit will make sure that your team has what they need before beginning a review. Conducting an audit will also help minimize slowdowns and hiccups when you kickoff the review.
3. Batch Prioritization
Not all Batches Are Created Equally.
On a lot of cases the client or tech vendor will decide to batch up all the documents without considering any overarching batching strategy. While this is common, we find that our review teams get a better result when we batch documents based on the facts of the case with a clear review strategy in mind. One way in which Special Counsel and D4 have gotten good results is batching potentially privileged documents together so they can be reviewed in a concentrated workflow. Clients need to be using a special keyword list containing terms that include all attorneys who may be contained in the documents. Be sure to include any specific terms that are likely to come up due to litigation (i.e. “lawsuit”, “settlement”, and even “litigation”).
You can run searches on those terms and set up batches according to the hit results of those searches once you’ve created a comprehensive keyword set. This allows reviewers to work on those batches with the understanding that they need to lend a critical eye to privilege issues and focuses the content of those batches to ensure the team is not constantly pivoting between different questions of law during their review. Ideally, you will not review privileged batches first. A veteran review team who has built up a competency with the core issues of the case can manage these documents.
The above tips and strategies provide a good starting point for kicking off your review on the right foot. However, every project is unique and therefore a unique approach is required for every case we work on.
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