Epiq’s client had to fulfill a Hart Scott Rodino Second Request, requiring production of responsive documents identified from a collection of more than 5 terabytes of documents. All the data had to be analyzed and reviewed so documents relevant to the merger could be delivered to the Department of Justice in 45 days.
Epiq forensically preserved all data and then systematically culled down the data set. By processing and technology-based data minimization techniques, Epiq reduced the data set by more than 96 percent prior to document review.
Based on its extensive experience with Second Requests, Epiq knew that it would likely be able to reduce the data set substantially by creating directory trees and interviewing custodians first and then further by applying keyword search techniques. Epiq’s understanding of techniques for managing redundant data allowed for a quicker and more efficient document review.
Epiq started by creating directory trees and – along with outside counsel – interviewed custodians to identify folders where data might reside, resulting in a reduction to 600 gigabytes. Epiq then applied data minimization techniques to cull the data set down to 300 gigabytes, which were processed for native review. Since 300 gigabytes still represents more than a million documents, Epiq then ran near-duplicate identification and thread compression technology, reducing the amount of email to be reviewed by 40%.