eDiscovery Daily Blog

• February 9, 2011

 

Yesterday, we discussed the assembling the project team for document review.  It’s also important that the review team gets good training.  As a starting point, prepare a training manual for each team member that includes this information:

• The document review criteria
• A list of the custodians.  For each, provide the custodian’s title, a job description, a description of his/her role in the events that are at issue in the case, and a description of the types of documents you expect will be found in his/her files
• Lists of keywords, key characters, key events, and key dates
• Samples of responsive documents that you collected when you reviewed the collection
• The review procedures
• The review schedule
• Instructions for use of the review tool

Cover these topics in training:

• Case background information
  • A description of the parties
  • A description of the events that led to the case
  • A description of the allegations and defenses
  • An overview of the expected case schedule
• Project overview information
  • A description of the goals of the review project
  • A description of the process
  • An overview of the expected project schedule
• Responsive criteria
  • Go through the criteria – point-by-point – to ensure that the group understands what is responsive
  • Provide samples of responsive documents
• Mechanics
  • Describe the roles of individuals on the team
  • Review the procedures for reviewing documents
  • Train the reviewers in use of the online review tool

Give the team training exercises – that is, give them sample documents to review.  Collect the work, review it, and give feedback to the group.

And let me give you two more suggestions that will help make your training effective:

1. Train the team together, rather than one-on-one or in sub-groups.  Under this team-training approach, you ensure that everyone hears the same thing, and that responses to questions asked by individuals will benefit the entire group.
2. Involve a senior attorney in the training.  You might, for example, ask a senior attorney to give the case background information.  Attention from a senior litigation team member is good for morale.  It tells the team that the work they are doing is important to the case.

How do you approach training a document review team?  Please share any comments you have and let us know if you’d like to know more about an eDiscovery topic.