3 Document Review Tips from eDiscovery Project Management Experts

Special Counsel 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. Clients come to them daily with questions like, “have you ever seen this before,” or “how have your other clients handled something like this,” and 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 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. In particular, the dynamic relationship between our managed review project managers and the D4 technical litigation support project managers is consistently a hot topic among our clients as they are eager to learn from the synergies we’ve been able to create and their cost saving effects downstream. We have also complied some helpful tips to improve your document review process to obtain the best results in an efficient manner.

To discuss some of the specifics in your case and to learn what Special Counsel & D4 can do for you, reach out to us to schedule a consultation.

In an interview with our technical PM team, they shared some of the “hacks” they find most impactful when working with a review PM and 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. Never underestimate the power of email threading – 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 and it often leads to longer review times as reviewers duplicate their work across several copies of the same email discussion.

Additionally, extra care has to be taken by the 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 and are able to review with the confidence that they have all pertinent information in front of them when they make a coding decision.

2. Use Your Review Project Manager Early & Often

Nothing Good comes to those who wait. Use your Review Project Manager Early & Often – One common problem that we see at Special Counsel & D4 is the review PM’s 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 will allow that PM to understand the issues at play, as well as giving the client the 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 to make sure that the team has what they need before you begin a review. This will help minimize slowdowns and hiccups when you kickoff the review.

3. Batch Prioritization

Not all Batches Are Created Equally. Batch Prioritization –  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. To do this we suggest our clients use a special keyword list containing terms that contemplate all attorneys who may be contained in the documents, as well as any specific terms that are likely to come up due to litigation (i.e. “lawsuit”, “settlement”, and even “litigation”).

Once a comprehensive keyword set has been created searches can be run on those terms and then batches can be set up according to the hit results of those searches. 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, privileged batches will not be the first documents reviewed, and should be tackled by a veteran review team who has built up a competency with the core issues of the case.

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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