My responsibilities include:
- Drafting discovery responses, objections, and electronically stored information (“ESI”) protocols providing the parties’ agreed upon production sources, format, and other considerations.
- Advising clients on hard-copy document and ESI preservation obligations during the pendency of a lawsuit and relaxation of such obligations after litigation has concluded.
- Preparing litigation holds and advising on procedures for implementation, including identification of relevant custodians and data sources to which the litigation hold should apply, as well as providing direction regarding release from the litigation hold.
- Briefing on E-Discovery issues, including research on the local and Federal rules related to E-Discovery, motions for protective orders, and responses to motions to compel.
- Preparing draft case management orders and Rule 26(f) reports, and strategies for Rule 26(f) conferences.
- Serving as a liaison between clients, IT personnel, and outside service providers on support for proportionality objections, including producing affidavits and identifying and preparing witnesses to testify on burdensomeness of collecting and producing data from particular custodians and sources.
- Consulting with clients on ideal methods for collecting, processing, reviewing, and producing relevant hard-copy and ESI data.
- Develop or update record retention policies and effectively implement those policies.
- Coordinate a broad team that may include in-house counsel, other attorneys and legal staff, IT professionals, and employees with record retention responsibilities.
- Manage firm personnel, document review service providers, and technology process providers in order to ensure that the right individuals are utilized for a cost-effective and legally proportional response to discovery obligations.