Ice Miller has experience in every portion of the e‑discovery life cycle.  Its e‑discovery services include:

  • Drafting document retention policies.
  • Consulting on the content and execution of litigation holds.
  • Preparing e‑discovery protocols and case management plans addressing e‑discovery issues.
  • Managing the work of vendors and IT personnel as they process data.
  • Designing, negotiating, and effectuating search culls to reduce irrelevant data before the review process is commenced.
  • Identifying appropriate review platforms.
  • Conducting reviews of data using associates, project attorneys, and paralegals.
  • Implementing procedures to increase the quality and efficiency of review projects.
  • Briefing e‑discovery issues such as whether certain discovery requests impose an undue burden on the client.
The review of electronic data is often the most time-consuming and substantively important portion of the e‑discovery life cycle.  Ice Miller has had extensive experience designing and managing large electronic document review projects over the last decade, including numerous projects for multi-national pharmaceutical, manufacturing, and services companies.  These have included projects supporting the defense of multiple product liability lawsuits, commercial disputes, and regulatory compliance filings, as well as proactive, confidential internal reviews.

Several Ice Miller attorneys have accumulated years of experience in the e‑discovery area.  In addition to designing and administering e‑review projects, they have participated in the development of Indiana’s e‑discovery rules, spoken before judges and other groups on e‑discovery issues, and served on committees assisting in developing e‑discovery practices for Indiana and Ohio courts.

One of the positive results of Ice Miller’s e‑discovery experience is that it has developed a strong team of attorneys and paralegals who are very skilled in e‑discovery and review work.  More than ten partners and 20-25 current associates and paralegals have experience in e‑review projects, and several associates have administered projects.  In addition, the firm is fortunate to have a core group of very experienced project attorneys, including several Ice Miller alumni, who are familiar with a wide variety of review methods and platforms.  The firm also has an experienced and capable IT/Litigation Support staff.

Ice Miller’s e‑discovery experience has enabled it and its clients to develop and refine methods that increase the efficiency and effectiveness of its projects. Regular review team meetings, updates through FAQ documents, interaction with the trial team, and frequent communication with clients help review projects provide maximum value.  Ice Miller also keeps current on rapidly-occurring technological changes, as many of them can greatly increase efficiency and reduce expense.

Representative Experience

  • Designed and administered projects supporting defense of multiple product liability claims in several jurisdictions simultaneously; projects included both review and production of client’s data and the identification of information relevant to depositions of client’s employees.
    • In cases involving product A, approximately 1.1 million pages reviewed; 609,000 pages produced.
    • In cases involving product B, approximately 760,000 pages reviewed; largest single production approximately 300,000 pages.
  • Proactive pre-litigation review for product: Approximately 3.4 million pages reviewed.
  • Construction litigation:  Approximately 2.5 million pages reviewed; 351,000 pages produced; other parties’ documents of similar volume also reviewed and analyzed to support defense; project also included handling of information in copy of live database.
  • Commercial dispute:  Original set of documents totaled approximately 4 million pages before culling; approximately 500,000 pages reviewed, 96,000 pages produced.
  • Proactive review of contracts (no litigation):  Original set of 10,000 contracts identified for potential review, reduced to 3,000 and then to 1,400 using strategies developed by Ice Miller and client.
  • Administered two related projects in which a team of approximately ten lawyers produced over 180,000 documents (more than 2.4 million pages) in less than 12 months.
  • Working with small team of two or three reviewers, oversaw review of more than 500,000 pages and production of 10,000 pages in commercial dispute.
  • Represented international manufacturer in lawsuit involving the recall of over 50,000 vehicles.  The case required the collection and processing of over 500 gigabytes of data, including a legacy database, and a complex review involving multiple project attorneys. Utilization of new technology, especially "near-duplicate" functionality, helped speed the document review and significantly reduced review costs.

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