Assisting Am Law 50 Law Firm with Aggressive Discovery Deadline

The Challenges

PLUSnxt recently assisted a client with a high-pressure discovery response involving a huge set of data to a government agency within an extremely aggressive discovery deadline. Our client learned well into in the case that the volume of data was considerably larger than expected which led them to try to negotiate to get the case dismissed or push the deadline back, but both efforts were unsuccessful.

As a result, our client considered a rolling production process (to get at least some of the data produced within the deadline) and/or production of all documents and families responsive to search hits without review (with subsequent clawback of any inadvertently produced privileged documents identified). The challenges associated with this case included:

• There were 3.4 terabytes (TBs) of data that was potentially relevant in this case, primarily stored in Microsoft 365 (M365).
• Our client had already collected roughly 200 hundred gigabytes (GBs) of data to be processed for review, but most of the data still needed to be collected. All of the data still needed to be ingested, processed, analyzed, reviewed and produced.
• The proposed time-consuming collection process involved a forensic team downloading the data from M365, shipping the data to the PLUSnxt team, who would then upload the data.
• The production deadline established by the government agency was 30 days.

The Solution

PLUSnxt’s team of experts recommended and implemented a more streamlined approach to collecting the data. Instead of having a forensic team download and ship the data to PLUSnxt for uploading, the PLUSnxt team worked with the client to push the data (in a series of batches) from the M365 environment directly into RelativityOne, which is located on the same backbone and in the same data center.

PLUSnxt’s team of experts then performed early case assessment (ECA) on the data corpus, using the analytics capabilities of RelativityOne and keyword searching to cull the collection for loading into the review database, then produced responsive documents and families via secured FTP as required by the government agency. The PLUSnxt team was able to address the above challenges to achieve the following results using RelativityOne:

• Processing and loading of the entire data corpus over a single weekend due to the streamlined approach of pushing the data directly from M365 to RelativityOne.
• Extensive culling of 3.4 TB of data using RelativityOne’s ECA capabilities.
• Executing two iterations of search terms as our client  adjusted terms after the first iteration.
• Leveraging RelativityOne’s efficient review capabilities to review the entire set of potentially responsive documents without needing to consider the use of its Continuous Active Learning (CAL) capabilities.
• Producing the entire responsive document set of 355,000 documents (approximately 1 TB of data) within 28 days, via secured FTP (over a series of batches due to data size transfer limits of the FTP).

The Benefits

The customized approach that PLUSnxt’s team of experts used to streamline the data collection process and the efficient approach to culling and review using RelativityOne enabled our client to meet the production deadline without having to consider rolling productions or production of search results without review. This enabled our client to achieve a major accomplishment for their client in responding to the government agency request in a timely manner. This is an example of how PLUSnxt’s creative approach throughout the eDiscovery lifecycle and their technical expertise with RelativityOne can enable clients to meet extremely aggressive discovery deadlines, even with huge data volumes.