New York Practice · 02

ESI handled so the process never becomes the issue.

eDiscovery is the identification, preservation, collection, processing, review, and production of electronically stored information in litigation or an investigation — managed so that each step remains defensible if an opponent challenges it.


Discovery disputes rarely turn on what a document says. They turn on how it was collected, what was culled and why, whether the hold went out in time, and whether the production can be explained. A process that cannot be described precisely becomes the litigation.

We run eDiscovery end to end for New York matters — from the first hold notice through production and load files — and we document the decisions along the way. Where counsel already has a platform and a workflow, we consult into it rather than replacing it, and we can serve as the neutral or the testifying expert when the methodology itself is contested.

What we deliver

  • Legal hold & preservation
  • ESI collection & processing
  • Hosted document review
  • Technology-assisted review (TAR)
  • Production & load-file management
  • eDiscovery consulting & protocols
Method

How the engagement runs

  1. Hold and scoping

    We help identify custodians and data sources, issue and track a defensible legal hold, and agree the scope before collection begins — the stage where most later disputes are won or lost.

  2. Collection and processing

    ESI is collected forensically from devices, servers, cloud tenancies, and messaging platforms, then processed, de-duplicated, and culled with the decisions recorded.

  3. Review

    Documents are hosted in a secure review platform. Where volume justifies it, technology-assisted review reduces the population that human reviewers must read without sacrificing defensibility.

  4. Production and defense of process

    We produce in the agreed format with clean load files, and we stand behind the methodology — in a meet-and-confer, a motion, or testimony.

In New York

Why the jurisdiction matters

New York's Commercial Division maintains its own rules and guidelines addressing electronic discovery and proportionality, and the federal courts here apply the proportionality standard of Federal Rule of Civil Procedure 26(b)(1). Both reward parties who can articulate a defensible process early and penalize those who improvise it after a challenge.

Our protocols are written to be handed to opposing counsel and to the court, not merely used internally.

Questions

eDiscovery — common questions

As soon as litigation is reasonably anticipated — which is usually earlier than it feels. The hold does not need to be perfect to be effective, but it does need to be timely, documented, and actually enforced against the systems that are deleting data on a schedule.

Yes, when the workflow is documented and the validation is real. TAR has been accepted in courts for well over a decade. What draws challenges is not the technology but an unexplained process: undocumented seed sets, no validation sampling, and no one able to describe the methodology under questioning.

Yes. Many matters arrive with a platform, a vendor, and a workflow already in place. We consult into that environment, and where the existing process has a defensibility gap we say so and help close it rather than starting over for its own sake.

The person who designed and ran it. Our eDiscovery professionals write their own protocols and defend them, and our experts have testified on discovery methodology and data handling in courts and arbitral forums.

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Related

Other New York disciplines

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