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Lucille Brown is a new associate at Johnson and Smith, LLP.  Orientation has completed and it is time for Ms. Brown’s first assignment. Let’s see how she does. 



Memorandum

From:                  David Johnson: Partner, Johnson and Smith, LLP

To:                       Lucille Brown, Associate

Date:                   Tuesday, July 25, 2023 at 4:00 pm.

Regarding:          Upcoming Depositions in the Bottled Water Matter

Hello Lucille and welcome to the firm. We need your help right away.

Our client is a citizens group concerned about how Florida administrators are allowing private companies to extract water from the aquifer and sell it as bottled water. There are concerns that the companies are depleting the aquifer, causing sinkholes to swallow homes and more.

We sent out this request for production: “All documents evidencing, reflecting or pertaining to the extraction of water in Florida for bottling by commercial enterprises.” Depositions are not yet scheduled but we need to know who to depose from which companies and which government officials are involved in the decision making process. Ideally, we would like to know who is in whose pocket in this business.

We need your response ASAP, hopefully by the end of the week. Depositions start next Monday, July 31st.

Memorandum

From:                  Lucille Brown

To:                       David Johnson

Date:                   Tuesday, July 25, 2023 at 4:30 pm.

Regarding:          Upcoming Depositions in the Bottled Water Matter

Based on the document summaries, several key individuals and companies have been identified that are involved in the extraction of water in Florida for bottling by commercial enterprises.

The companies that are frequently mentioned in the documents are Perrier and Nestle, specifically Great Nestle Waters of America (Document 000381Document 065151Document 059464Document 048973Document 052941Document 128199). These companies have been extracting water from various springs in Florida, including Crystal Springs and Madison Blue Springs.

In terms of individuals, Brad Willis, Vice President of Save our Springs, Inc., is a key figure who has been actively expressing concerns about the extraction of water in Florida for bottling by private companies (Document 000381Document 065151Document 051585Document 060299Document 088496Document 076386Document 048973Document 052941Document 059629). He has been communicating directly with Governor Jeb Bush about these issues.

Governor Jeb Bush is another key figure who has been involved in the decision-making process (Document 054609Document 000381Document 066592Document 065151Document 059464Document 051585Document 060299Document 088496Document 059487Document 124225Document 076386Document 059848Document 048973Document 052941Document 175955Document 055529Document 059490Document 030512Document 145821Document 068029Document 145620Document 053518Document 059629Document 149274Document 055702Document 059490Document 032646Document 140281Document 064781). He has received numerous emails from concerned citizens and organizations about the extraction of water in Florida for bottling by commercial enterprises.

Raymond Ludwig, Brad Willis, Virginia Seacrist, Paul A. O’Byrne, Lynn McGarvey, Teresa L. Weaver, and John Nowlen are among the citizens who have expressed their concerns directly to Governor Bush (Document 054609Document 000381Document 066592Document 065151Document 059464Document 059487Document 124225Document 055529).

M. Lane Stephens, a governmental consultant for Perrier, has been in communication with Governor Bush, expressing Perrier’s concern about water conservation and their desire to be more involved in addressing the water shortage in Florida (Document 069160).

In terms of government officials, David Struhs and Bob Sparks have been mentioned in the documents (Document 066592Document 145821Document 001625).

In terms of potential corruption or “who is in whose pocket”, there are several documents that suggest a close relationship between the companies extracting water and the government officials. For example, M. Lane Stephens, a governmental consultant for Perrier, has been in communication with Governor Bush, expressing Perrier’s concern about water conservation and their desire to be more involved in addressing the water shortage in Florida (Document 069160).

In another document, Denver Stutler, Mike Joyner, and Jeb Bush discuss the extraction of water from Silver Springs in Florida. Stutler forwards an email from Teresa Weaver to Governor Jeb Bush, expressing concern about the pumping and selling of water from Silver Springs. Joyner provides an explanation that no one is pumping from Silver Springs directly, but rather a company called Dickson Trust has a permit to extract water from nearby wells owned by Silver Springs Regional Water Inc. Joyner also mentions that Dickson Trust pays a monthly removal fee to the county (Document 145821).

These documents suggest that there may be a close relationship between the companies extracting water and the government officials, which could be a potential area of investigation for the firm.

In terms of a timeline, the documents span from 1999 to 2006, with the majority of the documents dated in the early 2000s. This suggests that the extraction of water in Florida for bottling by commercial enterprises has been a concern for at least a decade.

I hope this information is helpful for your case. Please let me know if you need further assistance.


Memorandum

From:                  David Johnson

To:                       Lucille Brown

Date:                   Tuesday, July 25, 2023 at 4:45 pm.

Regarding:          Upcoming Depositions in the Bottled Water Matter

Thanks for your quick response. 

Who should we depose and why? What topics should we cover and what documents should I include for each?


Memorandum

From:                  Lucille Brown

To:                       David Johnson

Date:                   Tuesday, July 25, 2023 at 5:00 pm.

Regarding:          Upcoming Depositions in the Bottled Water Matter

Based on the document summaries, here are some suggestions for depositions:

Based on the document summaries, here are some suggestions for depositions:

1. Brad Willis, Vice President of Save our Springs, Inc. (Document 000381Document 065151Document 051585Document 060299Document 088496Document 076386Document 048973Document 052941Document 059629): Willis has been actively expressing concerns about the extraction of water in Florida for bottling by private companies. He has communicated directly with Governor Jeb Bush about these issues. Topics to cover could include his knowledge of the companies involved, the impact on the environment, and any interactions or communications he has had with government officials.

2. Governor Jeb Bush (Document 054609Document 000381Document 066592Document 065151Document 059464Document 051585Document 060299Document 088496Document 059487Document 124225Document 076386Document 059848Document 048973Document 052941Document 175955Document 055529Document 059490Document 030512Document 145821Document 068029Document 145620Document 053518Document 059629Document 149274Document 055702Document 059490Document 032646Document 140281Document 064781): As the governor during the time these issues were raised, Bush would have knowledge of the decision-making process and any potential influence from the companies involved. Topics to cover could include his knowledge of the companies involved, any communications or interactions he has had with these companies, and the decision-making process regarding the extraction of water.

3. Representatives from Perrier and Nestle (Document 000381Document 065151Document 059464Document 048973Document 052941Document 128199): These companies have been extracting water from various springs in Florida. Topics to cover could include their extraction practices, any communications or interactions they have had with government officials, and their response to concerns about the depletion of the aquifer.

4. M. Lane Stephens, a governmental consultant for Perrier (Document 069160): Stephens has been in communication with Governor Bush, expressing Perrier’s concern about water conservation and their desire to be more involved in addressing the water shortage in Florida. Topics to cover could include his role as a consultant, his communications with Governor Bush, and any knowledge he has about Perrier’s extraction practices and interactions with government officials.

5. David Struhs and Bob Sparks (Document 066592Document 145821Document 001625): These government officials have been mentioned in the documents and may have knowledge about the decision-making process and any potential influence from the companies involved. Topics to cover could include their role in the decision-making process, any communications or interactions they have had with the companies involved, and their response to concerns about the depletion of the aquifer.

For each deposition, you should include the relevant documents that mention the individual or company. These documents provide evidence of their involvement in the extraction of water in Florida for bottling by commercial enterprises and their knowledge of the concerns raised by citizens and organizations.

A Real Life Story? 

Not yet,  but soon enough. You have correctly deduced that the associate is GPT 4.0. In real life, the project might take several days to complete with a (really smart) human associate doing the work. At a billing rate of $500 an hour, the associate’s analysis might cost $10,000 or more .

With GPT and our B2 system, the actual process completed in minutes. My hypothetical associate actually held off sending the response to give the appearance of being hard at work. The whole project cost about $1.00 in LLM costs.  

Is this a real life story? It will be in the near future. Integrated systems like B2 (our internal lab name) can do the following in minutes rather than hours or days:

  1. Review and analyze the memo text (in exactly the form presented above);
  2. Create a search across the 290,000 Bush emails in our lab test set;
  3. Run the search, identifying the 1,000 most likely relevant documents (this is configurable;
  4. Summarize all 1,000 documents based on the topic request;
  5. Rank all 1,000 documents based on likely relevance (0 to 10);
  6. Sort the document summaries in relevance order, top to bottom;
  7. Send the document summaries to GPT to use for its analysis;
  8. Receive GPT’s analysis complete with live links to the summaries and original emails. 

Welcome to a new era of Discovery. It’s a world where we can seamlessly transition from search hits to discovery answers, thanks to the extraordinary capabilities of AI.

By seamlessly integrating an LLM with an algorithmic search engine like Sherlock, legal professionals can harness the immense capabilities of large language models to  streamline discovery processes and quickly dive deeper into the key documents that are most relevant for the case. 


Appendix

If you want to see the process behind the scenes, here are screenshots from B2 for the discussion we had on the Bottled Water Case.

The Initial Question

We inserted the following prompt into B2:

The beauty of these LLMs is that you don’t have to learn specific syntax or language in order to communicate with GPT. Just enter your request as you might working with a human associate. 

Finding and Summarizing 300 Documents

In this case, we asked B2 to find and analyze the top 300 relevant documents. The process of doing so took about three minutes. Compare that to the alternative with human associates doing the research and analysis. 

Click on any summary to view its contents. Or open all of them with a click.

Viewing the Summaries

Here are views of the top two summaries prepared  by B2.

A screenshot of a report with summaries of the top 300 docs

Linking to the underlying emails

We can review the actual email text for each of the summaries.

GPT’s Analysis

After finding, summarizing and ranking the top 300 documents, GPT chooses the top fifty or sixty of them and starts providing its analysis. 

Our Further Question

And here is GPT’s response to our last question:

Prompt window with directions to search the jeb bush archives for depos

Authors

  • John Tredennick

    John Tredennick (JT@Merlin.Tech) is the CEO and founder of Merlin Search Technologies, a cloud technology company that has developed Sherlock®, a revolutionary machine learning search algorithm. Prior to founding Merlin Search Technologies, Tredennick had a distinguished career as a trial lawyer and litigation partner at a national law firm. With his expertise in legal technology, he founded Catalyst in 2000, an international e-discovery search technology company that was later acquired by a large public company in 2019. Tredennick's extensive experience is evident through his authorship and editing of eight books and numerous articles on legal technology topics. He has also served as Chair of the ABA's Law Practice Management Section.

  • Dr. William Webber

    Dr. William Webber (wwebber@Merlin.Tech) is the Chief Data Scientist of Merlin Search Technologies. With a PhD in Measurement in Information Retrieval Evaluation from the University of Melbourne, Dr. Webber is a leading authority in AI and statistical measurement for information retrieval and ediscovery. He has conducted post-doctoral research at the E-Discovery Lab of the University of Maryland and has over 30 peer-reviewed scientific publications in the areas of information retrieval, statistical evaluation, and machine learning. Dr. Webber has nearly a decade of industry experience as a consulting data scientist for ediscovery software vendors, service providers, and law firms.

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