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eDiscovery Leaders Live: Michelle Six & Dan Raffle

George Socha
October 12, 2021

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Michelle Six and Dan Raffle of Kirkland & Ellis join George Socha, Senior Vice President of Brand Awareness at Reveal, for ACEDS #eDiscoveryLeadersLive.

Michelle is a partner in Kirkland’s New York office, leading the firm’s eDiscovery efforts. Dan is Associate Director Litigation Technology,

Michelle and Dan discussed the art of negotiating TAR agreements.

Key Highlights

  • [02:25] Setting TAR protocol goalposts.
  • [03:32] Knowing the rules of the road.
  • [04:03]TAR agreement pitfalls.
  • [06:02] How to go in informed.
  • [08:05] Figuring whether and when to use TAR at all.
  • [09:15] TAR subject to protocols: Most often to cull documents.
  • [09:43] TAR and search terms versus TAR or search terms.
  • [13:55] Whether to bake target numbers into TAR protocols.
  • [16:16] Ensuring lawyers don’t go rogue.
  • [17:59] What freaks people out about TAR – and what to do about that
  • [20:07] A higher standard for TAR?
  • [22:37] Threading and privilege…and TAR.
  • [28:10]Closing thoughts: the most important things you can do to successfully negotiate TAR agreements.

Key Quotes by Michelle Six & Dan Raffle

• Michelle: “The biggest pitfall, at least for me, is that there is no best practice or one way to do things.”

• Michelle: “Dan raised a really good point in that probably the first and most important thing to think about if you’re planning to negotiate a TAR protocol is where you need to use TAR…. I think TAR at its best is a process that can be utilized and leveraged to save on time, save on costs, to hopefully build a more efficient and accurate review….”

• Dan: “Before you burn time negotiating an order, make sure you know what you want to get and what the chances are of success.”

Connect with Michelle and Dan

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