REPRESENTATIVE EXPERIENCE
E-Discovery Analysis and Technology (e-DAT)
Litigation Readiness
Prepared litigation readiness plans for clients that provide legal advice and practical forms
and tools for records retention, litigation holds, collection, processing, and production.
e-Discovery Counsel
Served as primary coordinating e-discovery counsel, responsible for all aspects of preservation,
collection, review, and production, in related criminal, state, and federal court civil
proceedings arising from combustion and release events that occurred in the aftermath of
Hurricane Harvey.
On behalf of a privately held manufacturing and distribution company, served as e-discovery
counsel responsible for all aspects of preservation, collection, review and production, as well
as litigation support in an antitrust lawsuit.
Managed collections and document review for an oil spill case that secured a US$255 million
arbitration award for our client.
Represented a waste company as e-discovery counsel in class action over fees. Developed an
approach to calculating damages used to achieve a favorable settlement.
Managed all phases of discovery responses and trial support for a government client in major
public works construction litigation matters, both as plaintiff and defendant. One particular
outcome resulted in a US$26 million settlement for our client.
Managed ongoing electronic document review and productions for multiple patent litigation
matters on behalf of a pharmaceutical manufacturer.
Technology-Assisted Review/Continuous Active Learning
Represented a publicly traded, Fortune 500 worldwide supplier of technology-based railway
products and services as e-discovery counsel in patent infringement and trade secret
misappropriation lawsuits; responsible for all aspects of collection, review and production, as
well as litigation support. Managed large and complex document review projects using
industry-leading TAR tools.
Rule 45 Subpoenas
Prepared responses to third-party document requests to a mobile phone manufacturer in antitrust
lawsuits brought by competitors and class-action plaintiffs.
Deposition Preparation
Represented a local government entity as primary e-discovery counsel in an environmental
insurance coverage litigation involving more than 20 insurance carriers and spanning over 75
years, seeking coverage for environmental liabilities and clean-up costs associated with a
federal Superfund site. Managed a document collection of over 6 million documents from more than
100 custodians through effective use of both search terms and predictive analytics. Prepared
trial team in environment insurance coverage litigation for client and opposing party
depositions by running complex queries across document productions to identify key documents and
create witness and issue binders.
Reviewed and analyzed documents to create deposition preparation sets for a Rule 30(b)(6)
corporate representative for trial team review and use.
Trial Support
Represented defendant/counterclaim plaintiff in an antitrust suit that ended in a defense
verdict after six-month jury trial, with treble damages and attorneys’ fees awarded to client
(reversed on appeal). From 2007 to the filing of attorneys’ fees motions in 2014, managed all
aspects of discovery; factual research for both the legal and expert teams; pretrial processes,
including identifying exhibits and objections, deposition designations (more than 365 days of
testimony), preparation of documents for the in-court trial presentation system, and remote
trial support with on-site trial support by one lawyer for the duration of the trial. Also
supported post-trial attorneys’ fees application, including preparation of a database to capture
all time entries classified by category for submission.
International Arbitration
Advised on client’s response to a grand jury subpoena in an investigation that concluded with no
action being taken against our client. Presented sufficient information to the government to
convince them to relax their original stance on both the scope of backup tape preservation
required and the permissibility of cross-custodian global deduplication and email threading,
substantially reducing the client’s preservation and production costs.
Government Investigations
Represented an automotive parts distribution company in a Federal Trade Commission investigation
of a proposed acquisition by a major competitor (HSR Second Request).
Represented a telecommunications company in a government investigation relating to mobile phone
locking.
Served as e-discovery counsel for an electricity generation company in government and internal
investigations into compliance with environmental legislation and regulation.
Internal Investigations
For complex internal and governmental investigations, managed a document collection of nearly
7.5 million documents, using predictive analytics to significantly reduce document review
volume.
Advised a commercial finance and leasing company as e-discovery counsel for a data breach
investigation. Developed and implemented a strategy to analyze compromised data, assessed the
impact on data subjects, mitigated risks, and complied with notification obligations.
Data Breach Investigations
Assisted a client with reviewing current litigation holds and advised regarding dispensation or
retention.
Global Information Governance and Records Management
Counseled a nonprofit organization on best practices related to communications information
governance.
Prepared a record retention schedule, including specific record categories related to
construction-specific operations and government contractor record retention requirements.
Prepared an updated, extensive record retention schedule, including document categories for
credit unions, procurement, and maritime records related to vessels, ports, and maritime
employees.
Prepared and updated a record retention schedule, including loan, banking, and credit records.
Prepared record retention schedules, including record categories specific to commercial loans,
mortgages, and banking records.
Prepared CORE record retention schedule, and performed additional specific research regarding
unique document types relating to radiation materials, laboratory records, clinical and
non-clinical study records.
Prepared a new record retention schedule for a biopharmaceutical solutions organization,
consolidating two legacy schedules from merged companies with extensive clinical trials/research
record categories.
Prepared a new record-retention schedule containing the longest legally mandated retention
requirement based on a 50-state and federal survey and conducted further research regarding
additional FDA record-retention requirements for companies selling food or supplement products.
Conducted contract review and analysis in the agribusiness sector through various stages of due
diligence review, including pre-auction, after-bid win, and preparation of a closing binder for
the acquisition of a national farmland portfolio by a private investment company.
Corporate Due Diligence/Mergers & Acquisitions
As part of a global retailer's transfer of licensing contracts from a Luxembourg entity to a
U.K. entity, used smart contract analysis technology to analyze a collection of 500+ contracts,
determining each contract's governing law, assignment, notice and VAT provisions, and any
available contact information for providing notice.
