An eDiscovery Role-Play Simulation Chamber: An eDiscovery Role-Play Cast James Beam (protagonist)…………………………………….Gene Eames, Pfizer Inc. Jonathan Walker, Esq. (antagonist)……………………….Brett Durand, Pfizer Inc.

Fictitious Pricing Scheme (for illustrative purposes only) 1 Custodian = 10 GBs of Data 1 GB Data = $100,000 to process, review, produce $10,000 to process $85,000 to review based on $1/document $5,000 production 1 Custodian = $1 Million total eDiscovery costs

Legal Holds (the wrong way)

Legal Holds (the better way)

$866 Million cost avoidance Custodians Data (GB) Documents Costs 875 8,750 525,000,000 $875,000,000 15 150 9,000,000 $15,000,000 $866 Million cost avoidance Start small: only process and review documents from the custodian(s) most relevant to the claim(s) Over 90% responsive documents will belong to 15% or less of custodians on hold

Make sure you’re looking in the right haystack(s) Documents Costs w/o Search Terms 9,000,000 $9,000,000 w/’ACME’ 6,000,000 $6,000,000 w/o ‘ACME’ 1,000,000 $1,000,000 Search terms alone are not enough – they need to be the ‘right’ search terms. Refine, include and exclude search terms based on sampling for responsiveness Make sure you’re looking in the right haystack(s)

Single-instance Review Documents Costs w/ Search Terms 1,000,000 $1,000,000 Threading 750,000 $750,000 Single-instance Review 500,000 $500,000 Optimize investment in review Review only the last email of a thread for responsiveness. Review identical documents once for responsiveness. If responsive annotate custodians who had the document.* * In some cases a document may become responsive based on the custodian it belongs to