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H5 eDiscovery Processing - 7 Tips for Reducing Stress (and Spend)


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In eDiscovery, good processing decisions early on can make a big difference. The collection is done and you finally have the data. Now what? What’s the best way to tackle processing without breaking a sweat, the bank, or your timeline?

Alongside early case assessment (ECA), this phase of eDiscovery presents an opportunity to undertake a defensible reduction of data and pass along only the material that will ultimately be necessary to review. Here are a few tips that may help.

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H5 eDiscovery Processing - 7 Tips for Reducing Stress (and Spend)

  1. 1. eDiscovery Processing: 7 Tips for Reducing Stress (and Spend) Erika Namnath, H5 You need it. We find it.
  2. 2. The collection is done. You finally have the data. Now what?    
  3. 3.   Here are 7 tips that may help:
  4. 4. Tip #1: Just because it’s been collected doesn’t mean you have to process it. Stop and think about what you’re after. •  Focus first on user-created content. •  Exclude obviously non-relevant files early on (e.g., system files, program files, Windows folders, other system-related data.)
  5. 5. Tip #2: Be prepared to recalibrate. Litigation is always evolving. Take into account: •  Was the collection early and broad? More may be known now. •  Has the focus of the matter changed? •  Have custodians been eliminated or added? •  Has the timeline changed?
  6. 6. •  Identify high-priority custodians. •  Only include data that fits the timeline. •  Zero in on email content. Tip #3: Prioritize the data. Reviewers can work on more relevant content while you supplement the data.
  7. 7. Try an ECA workflow to limit data and save time and money downstream. •  Use a DeNIST hash list to identify and remove common system files. •  Filter by file type and date range to eliminate data that’s out of scope. •  Eliminate “junk,” such s company email blasts. •  Dedupe and use email threading, if the situation warrants. •  Keyword cull, if you know enough and have sufficient expertise. Tip #4: Reduce, reduce, reduce.
  8. 8. Tip #5: Avoid blind (and costly) OCR. Only OCR pages that matter. •  Target image types that are likely to yield quality text, like TIFFS and non-searchable PDF’s. •  Consider letting those with non-usable text go. •  You can always run OCR on other image types later, if necessary.
  9. 9. Tip #6: Know what you’re leaving behind. •  Use random sampling to review excluded data. •  Use data landscape reporting to reveal suspicious omissions. •  Check a filename list to see if there’s anything of interest from source locations. •  Consider treating processing exceptions as pass- throughs for reviewers, just in case. •  Keep all processing content live so you can return quickly if scope changes. Rest easy by taking a few defensibility precautions.
  10. 10. Tip #7: Leverage expertise. •  Don’t underestimate the knowledge and ability of eDiscovery experts to provide guidance. •  Work with a vendor at each stage for less stressful, more efficient, and more defensible engagement. You don’t have to go it alone!
  11. 11. Erika Namnath is the Associate Director of Technical Services within the eDiscovery Group at H5. She focuses on litigation support services including media management, processing, imaging, and production. Erika is writing a series of articles about eDiscovery processing, hosting and production, featured on H5’s Blog, True North.