E-discovery in large-scale litigation involves the identification, preservation, collection, processing, review, and production of electronically stored information across organizations with complex data environments. Preservation obligations triggered by litigation holds require systematic coordination across business units, IT departments, and third-party data custodians to prevent spoliation and ensure compliance with court orders and regulatory directives. The volume of data at issue in these matters — frequently measured in terabytes — demands structured workflows and technology platforms capable of managing review at scale.

Proportionality disputes arise when parties contest the scope and cost of production obligations, requiring analysis under the framework established by the Federal Rules of Civil Procedure and applicable case law. The defensibility of e-discovery practices is itself a source of litigation exposure, as failures in preservation, processing, or production can result in sanctions, adverse inference instructions, or case-dispositive consequences. Where matters involve cross-border data, additional complexity arises from the interaction between domestic discovery obligations and foreign data privacy and data protection regimes.

• Design and implementation of litigation hold programs and document preservation protocols across large organizations
• Management of technology-assisted review and predictive coding platforms for large-volume document productions
• ESI collection, processing, and production in multi-party commercial litigation and regulatory investigations
• Proportionality and burden disputes under the Federal Rules of Civil Procedure and state procedural equivalents
• Defense against spoliation claims, sanctions motions, and challenges to the adequacy of e-discovery practices