1. 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.

2. 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

3. Legal Holds
(the wrong way)

4. Legal Holds
(the better way)

5. $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

6. 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)

7. 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 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