Planning Your Strategy Post Dawn Raid

Planning Your Strategy Post Dawn Raid

  • Blog Post
  • Posted on 1 November 2019

By Robyn Kidd, Head of Managed Document Review

A dawn raid led to the forensic collection of 100,000 documents. Where to from here?  It’s important to plan your strategy to minimise downtime, extract relevant documents and be ready for production.

Data Culling

Firstly, reduce the core data set to a manageable volume. There are a number of tools available, starting with de-duplication. De-duplication is applied globally and detects identical documents bearing the same MD5 Hash Values to remove exact copies of standalone documents. It also removes duplicate emails resulting from multiple custodian’s mailboxes being extracted and removing duplicate emails between mailbox custodians.  This can reduce the document set by 10-20%.

Email threading takes long chains of emails and removes all “early” emails, leaving just the final email chain for review (a potential reduction of 20-30% of an email set). It also recognises where emails split from the main conversation and prioritises the documents so the two chains are sequential. This enables reviewers to ascertain the stories behind the emails and review more efficiently.

There are also tools that can allow Early Case Assessment such as Foreign Language identification, Near Duplicate Analysis and Clustering.

Know What You’re Looking For

The next stage is to run some matter-specific identification of relevant material.  This can involve restricting the data set to the specified data ranges pertaining to your matter, further reducing the data set.  In addition, keyword searches should be run, identifying:

  • Potentially relevant documents for review;
  • Documents to be excluded;
  • Documents to be segregated for different review teams/levels; and
  • Key custodians to be prioritised or removed.

Consider whether your newly culled dataset would benefit from implementation of Technology Assisted Review (TAR) to either prioritise or further reduce the documents for review by using Artificial Intelligence – akin to Netflix suggesting a TV show based on previous TV shows watched.

Managing Your Resources

The next decision is - who will undertake the review; a review team in-house or hire additional resources? Alternatively, a third party with teams of reviewers could be engaged for First Pass Review, to cull irrelevant documents and allowing inhouse reviewers to focus on key documents and legal strategy. Consider whether you require foreign language reviewers or translation services and, depending on the matter, whether expert reports should be prepared.

Keep an Eye on the Clock

A final step – know your deadlines!  The timeline impacts decisions for resourcing, engaging experts and Counsel, and preparing evidence.

Spending time properly planning your project will save you time in the long run.


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