Todd Heffner: Filters, Curse Words and ‘Lessons Learned’: Tips on Discovery Searches

Extract from Todd Heffner’s article “Filters, Curse Words and ‘Lessons Learned’: Tips on Discovery Searches”

It’s now common that a case involves more documents than attorneys can lay eyes on—or should lay eyes on—for cost, time or other reasons. If you cannot or should not look at every single document and want to find the best documents in the shortest amount of time, these tips and tricks will hopefully give you some ideas for finding the best documents. A couple of caveats first. One, before considering any particular strategy mentioned below, it’s always important to understand why documents are being reviewed in the first place. Perhaps it’s for relevance prior to production, privilege review or to find potential hearing exhibits. For each of these situations, context matters—and not every strategy works for each type of review—so keep the big picture in mind. That said, most of the suggestions in this article will best be applied to reviewing incoming productions and for identifying problem documents within your own client’s documents.

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