eDiscovery Process

In earlier posts (here, and here) , I described AIIM’s Certified Information Professional certification.

Well I’ve been working my way through the training material, and got to the section on eDiscovery . Steve Weissman does a great job of describing the Electronic Discovery Reference Model (EDRM).

Electronic Discovery Reference Model.




The Identify Solution performs a full index of all data in place prior to collection, creating an auditable “data topology map” of active ESI, files, and email located on network servers, email servers, content management systems, storage systems, and PCs. Data topology maps are highly customizable to meet specific scan criteria, and they provide an automated and recurring way to identify ESI across unstructured sources, tag it, and apply business rules for eDiscovery.


The eDI Preservation Solution process allows documents that meet the preservation criteria to be searched in place, and then moved without the need for specialized collection tools. This process also authenticates collection and preservation by maintaining an audit log of the collection and by creating a hash value before and after collection. In addition, access control lists (ACLs) and security identifiers (SIDs) are preserved, proving file ownership as tracked by the file system.


In addition to traditional collection technology and methods, eDI has technology that provides on a solution that crawls and collects data on network servers, storage systems and personal computers, all without disrupting end users. No agent software has to be installed on PCs, and the solution is entirely transparent to users.

Culling and Processing

The collected documents, or the corpus, will need to be culled, based on the scope of the litigation and the information needing to be reviewed. Date range, document type, duplicate information, and keywords are a few of the methods used to reduce the corpus. At this stage the goal is to reduce the corpus down to a manageable size before human effort is expended.

The next step is to prepare the documents for a database review. Different tools have varying capabilities. Nor are cases identical, or the information required for them. As a result, processing will vary. In some cases, processing may occur all at one time and everything will be converted into its final production form of TIFF images. In other cases, the corpus will only go through light processing to make the native files suitable for review.


eDI provides a variety of cutting edge technologies that enable data analysis at virtually every stage of the EDRM model. These processes of evaluating a collection enable a rapid understanding of data that can enable the determination relevant summary information, such as key topics of the case, important people, specific vocabulary and jargon, and important individual documents early in each phase of ESI processing.

When a defensible workflow is combined with the eDI toolset, then user can be presented with information essential to making better and more informed decisions about out to target and process the ESI collection.


There are a number of ways and tools that can be used to review the corpus. Paper, TIFF, database, and native documents are all examples of forms in which a review can take place. Over a given case, the process you use will likely incorporate all of these forms. Information needs to be portable, and in most cases that will require good planning and consensus with all involved.

The goal of this step is to reduce the corpus down to the set of documents you are going to produce and use in the case. Without proper planning, this step can be lengthy and costly. There are a number of strategies that can be used to reduce both.


With the corpus down to relevant documents, it is now time to produce them to the opposing counsel. Typically both sides have agreed upon their exchange methodologies during the discovery planning process. These include paper, TIFF or PDF images with a database of metadata. In increasingly more cases, parties are exchanging data in native form or in native with metadata extracted.


Paper Discovery Reference Model (PDRM)

The link here leads to an amusing article that maintains that the Electronic Discovery Reference Model is actually nothing new…


  • An Introduction to E-Discovery (Part 1)
  • Information Management: The Foundation of the Electronic Discovery Reference Model
  • An Introduction to E-Discovery (Part 2)
  • Information Governance and eDiscovery
  • “A Little E-Discovery Checklist”
  • eDiscovery Daily Blog: eDiscovery Best Practices: EDRM Data Set for Great Test Data
  • Secrets of Search – Part One
  • The EDRM is a four-letter …
  • Skype in eDiscovery
  • Beware Of Dupes

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  1. Pingback: New Frontier for Electronic Discovery | strategicdefenselaw

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