Cutting Discovery Costs With Remote Foreign Custodian Interviews
As discussed in E-Discovery: Taiwan Collection on a Shoestring, CLP recently faced the challenges of cutting the discovery costs of a Taiwan based wireless communications device manufacturer with a popular new technology under dispute with a competitor.
For cost sensitive clients, containing discovery costs obviously requires reducing the overall volume of documents that will be collected, uploaded, processed and produced. If one looks at the Electronic Discovery Reference Model, ("EDRM”), the industry standard for approaching discovery,you will quickly realize that the most effective way to cut total costs along the discovery pipeline is to decrease the input during collection.

With our client, we knew our end goal was to decrease the number of irrelevant documents we collected. The most cost effective way of limiting the collection, we decided, was to work with the person most knowledgeable about the documents on the custodian’s workstation--- the custodians themselves--- to make a targeted collection instead of a full replica of the hard drive.
The challenge, then, was how to effectively work with Taiwanese custodians when travel costs to Taiwan could be 3k an attorney.