Innovations: Litigation Hold Notices – Using Excel and OneDrive


Lili Sorondo Rosenberg

As a Director of Delivery, Lili Rosenberg oversees eDiscovery matters on behalf of some of the leading U.S. law firms and multi-national companies.

Specializing in FCPA cases, she has managed multiple foreign language reviews on behalf of major retailers and their Latin American subsidiaries.

Prior to joining Special Counsel, Lili's area of practice was focused on international tax
compliance and employment litigation matters, representing both companies and individuals.

As part of ongoing litigation reviews handled by Special Counsel, an end client requested our assistance with a Litigation Hold Review: we were tasked with drafting legal hold notices for individual cases. From the onset, the end client’s general counsel has been steadfast in his stance that the end client did not want to utilize Relativity as part of the legal hold process. In order to meet the client’s requirements, Special Counsel and the law firm have partnered closely in a collaborative effort to navigate the end client’s internal systems and processes.

By way of background, the law firm initially makes a litigation hold recommendation which hinges on the relevant geographic scope for each case. The actual drafting of the legal hold notices requires Special Counsel’s use of the end client’s internal personnel spreadsheets to determine which relevant current and former employees might have discoverable information related to a particular case in their possession.

As the end client’s legal team continually emphasizes the need for efficiencies and the requirements evolve, Special Counsel’s role in the legal hold process has grown substantially, including taking on several tasks which were initially handled by the law firm.

As the Lit Hold process has evolved, our team has developed a process by which to seamlessly exchange information via the use of excel spreadsheets and OneDrive. Spearheaded by one of our excellent Managing Attorneys, Wendy Morris-Campbell, this collaborative effort with the law firm involves the use of multiple excel spreadsheets designed to track both general case information and legal hold statuses. The law firm attorneys have immediate access to this information which allows them to provide Special Counsel with QC feedback and approval recommendations. We’re able to use this methodology to provide the end client with immediate work product. In essence, all stakeholders have the ability to track each phase of review at any point in time by utilizing OneDrive.

It is worth noting that Special Counsel is generally the only party involved at all stages of the Lit Hold review. Accordingly, our team has taken on the task of reconciling the case tracking methodologies used by The law firm and The end client in efforts to reduce duplicative work. This also allows all parties involved to quickly and efficiently access the status of a case file and legal hold notice at a particular point in time.

In a Nut Shell: A Summary of the Lit Hold Review Process


The law firm uploads cases to OneDrive for the team to review each day. If there are missing cases, the law firm will either provide Special Counsel with the documents to upload them onto OneDrive or assign a paralegal to resolve this issue.

Step 1

The Special Counsel team analyzes and copies certain Plaintiff allegations related to geographic scope from each case into a supporting Word document. Our team then provides the law firm with a recommendation on the relevant geographic scope and a colored map, at which point the law firm will review this information internally and either approve our recommendation or request modifications. Once approved, the law firm is tasked with drafting the legal rationale for the recommended geographic scope.

Step 2

Once Special Counsel receives the law firm’s approval of the recommended geographic scope, we’re tasked with gathering additional case information for the end client’s internal use. This includes identifying the end client’s stores within the recommended geographic scope. The case and supporting documentation are then uploaded to a case tracking spreadsheet on One Drive which lists current cases and the law firm’s corresponding recommendations and rationale. 

Step 3

Once the end client’s legal team approves the information gathered and uploaded in Step 2, we’re tasked with drafting the actual legal hold notices. The team accomplishes this task with the use of personnel spreadsheets provided by the end client. These spreadsheets are used to identify the relevant associates subject to the legal hold notice for a particular case. It is often the case that these spreadsheets are incomplete and lack the requisite associate information. In these instances, we will conduct research to obtain the necessary data. Once the letters are drafted, they are posted to OneDrive and reviewed by the end client. Special Counsel then indicates the completion of the letter on the end client’s legal hold tracker spreadsheet. In addition, the lists of relevant associates is added to separate spreadsheets maintained by the end client on OneDrive.

Special Counsel is dedicated to creating solutions for all of our clients that fit their needs and create efficiencies. The above is just one example of the unique solutions we have provided to clients to meet their needs. For more information, reach out to your local branch today.

Lili Sorondo Rosenberg is a Director of Delivery for EQ, the legal consulting division of Special Counsel. Connect with Lili via LinkedIn or email.

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