Meet & Confer Preparation
Lighthouse consults with clients prior to the Rule 26 conference to ensure they are prepared to suggest keywords and custodian limitations that have been tested on the actual case data. Lighthouse develops search methodologies in collaboration with clients and conducts search term sampling to determine the effectiveness and accuracy of proposed search terms so that Lighthouse clients enter Rule 26 conferences armed with detailed information about the documents at issue in the matter.
Keyword Search Consulting
Keyword searching is a critical step in reducing data to a manageable set for review and production. If not employed with care, it can mean failing to produce relevant documents, increased time and cost associated with reviewing too many non-responsive documents, and even court sanctions.
As one court admonished, "where counsel are using keyword searches for retrieval of ESI, they at a minimum must carefully craft the appropriate keywords, with input from the ESI's custodians as to the words and abbreviations they use, and the proposed methodology must be quality control tested to assure accuracy in retrieval and elimination of 'false positives.'"William A. Gross Constr. Assocs., Inc. v. Am. Mfrs. Mut. Ins. Co., No. 07 Civ. 10639, 2009 WL 724954, *3 (S.D.N.Y. Mar. 19, 2009).
Based on our years of experience and technical expertise, including computational linguistics professionals, Lighthouse ensures clients that their keyword searches are defensible, and helps clients develop creative strategies for reducing their data. Lighthouse:
- Helps construct search terms and queries.
- Advises clients on the best strategy for reducing their data.
- Conducts search term sampling to determine the effectiveness and accuracy of search terms.
Search Term Sampling
Using industry leading methods, Lighthouse can test clients’ keywords to determine the effectiveness of those terms. This sampling will reveal false positives and potential missed terms, thereby creating a more accurate and specific set of keywords and significantly reducing the junk data that too-general keywords often return.
Custodian Analysis
Lighthouse can conduct a custodian interaction analysis, which entails instantaneously analyzing the data to generate a report on key custodians or potential deponents that shows who they communicated with and how often. This can help litigants in a number of ways: identifying additional custodians that may have been overlooked, understanding relationships between key players, interviewing witnesses, and preparing for depositions.
