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Not Just Another Article on e-Discovery Review

By Allen L. Gurney
August 28, 2007

I, and my fellow electronic discovery veterans, have authored thousands of prescriptive articles offering sage advice on how to best improve and conduct an e-discovery review. Our industry often talks about 'best' like they are non-intuitive or otherwise so unique that only the truly gifted and inspired can attain such vaulted status. In truth, I believe that the best e-discovery review best practices are better characterized as the application of real-life lessons. I believe they are not complicated, and I further believe that focusing on a few of these learned lessons with a thoughtful, deliberate approach will achieve a truly effective electronic discovery review.

Plan, and Then Plan Some More

The absolute number one lesson is to plan. I would advocate that in nearly every project, e-discovery or otherwise, doubling (yes doubling) the planning effort for a project results in substantially greater returns than the additional investment. Take, for example, a large e-discovery effort involving 100 custodians, which not uncommonly can incur more than $5 million in review and e-discovery costs.

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