Page 2 - EDiscovery
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S2 | MONDAY, MARCH 16, 2015 | E-Discovery
| NYLJ.COM








BY CHRIS O’REILLY 
AND DAN MEYERS
E 
mails often comprise the bulk of the digi- 
tal documents involved in the e-discov- 
ery process of corporate litigation cases.
Depending on the case there could be 100,000, 
500,000 or one million emails, perhaps from 
around the world, involved at the outset. The 

task at hand is to electronically gather them 
together and identify only those that should 
actually be reviewed by an attorney because 
they may be relevant to the case.
This may seem like a daunting task, but 
with the availability of modern technology to 
gather emails and email threading software 
to organize them, it need not be.

In order to gain a grasp of the scope and 
potential cost of an email discovery project 
containing a large number of emails, it helps 
to reduce the sheer volume of emails to a 
common denominator. Digital documents like 
emails are measured in gigabytes, a term with 
which many people, including attorneys, may 
not be totally familiar.
For perspective, it may help to compare 

gigabytes to other commonly used measure- 
ments. The real estate world thinks in terms 
of square feet. Farmers plant crops based on 
anticipated price per bushel. Fuel eficiency is 
measured as miles per gallon. Gigabytes are 
no different. A single byte is equal to one char- 
acter of written digital text. A typical word is 
How Do You Handle
10 characters, or 10 bytes. A gigabyte then is 
1 billion bytes, which is roughly equal to the 

number of individual characters in a pickup 
500 Truckloads of Emails?
truck full of books. So, 500 gigabytes of emails 
would, if printed, ill 500 pickup trucks.

Capturing Designated Emails

To get this aspect of the e-discovery pro- 
cess started, unaltered copies of the initial 
Threading boosts eiciency and savings.
truckloads of emails must be captured. To 
accomplish this, a law irm or corporate legal 
department can choose to retain an e-discov- 
ery provider with technology to forensically 
copy, collect and store the emails. However, 
if they have the technical ability, they could



CHRIS O’REILLY is the CEO of LDM Global, an interna- 
tional e-discovery provider. DAN MEYERS is a partner 
at Bracewell & Giuliani in New York.
CK
TO
BIGS



Inside
E-Discovery


S4
Stay Clear of Form S6 Protective Orders
S8 Move Your Discovery S10 When Considering TAR, S
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Preservation Letters In the Age of Hacking Onto a Smarter Path It’s Never Too Late
Kris Fischer, Editor-In-Chief 
BY JOSEPH FRANCOEUR
BY DAVID J. KESSLER,
BY BARRY KAZAN
BY STEVEN M. AMUNDSON 
JAMI MILLS VIBBERT
AND MARK NOEL
Angela Turturro, Sections Editor 
AND ALEX ALTMAN
Agnieszka Czuj, Design
S

S

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