Updated December 9, 2010


  1. Involve Review team members early in the E-Discovery process and communicate often with them.
  2. Prepare, update, and distribute Review Guidelines as more knowledge is gained on the case.
  3. Meet-and-confer process with an eye to costs associated with specific requests before committing.
  4. Objectively consider in-house systems vs. hosted systems, and native production versus image files.
  5. Make sure review staff gets adequate training to use the review tools to maximum effect. Including identification of email threads, duplicates, near dupes will help speed the review. Take advantage of bulk tagging capabilities. Consult with the vendor to be sure you get the most out of your product.
  6. Use automation if available to speed privilege detection, privacy issues, and protected documents.
  7. Project management-appoint manager, determine deadlines, and track progress. Facilitate review team communications to update issue codes and areas of high interest. Set Realistic review goals.
  8. Share performance information with the review team so they can be aware of how their performance is being measured.
  9. Manage costs, prevent client cost surprises late in the review process (don’t blind-side the client).