· Sending litigation hold notices to opposing parties and potential witnesses.
· Collecting client Electronically Stored Information (“ESI”) per FRCP 34 or state equivalent, including email, texts and social media.
· Using ESI document management applications to store and access analyze clients’ and opposing parties’ ESI in a secure website.
· Using web--based review tools to identify ESI documents as responsive, , significant, privileged, related to witnesses, events or issues.
· Analyzing ESI including depositions to create document and deposition extracts organized by issue, witness or timeline for use in discovery and trial.
· Identifying and negotiating with opposing counsel on scope of relevant discovery under Rule 26, including date ranges, key search words as required or suggested by court rules.
· Assisting counsel with meetings and events required by FRCP Rule 26(f) or state equivalent relating to ESI, including Lawyer First Meeting and Report, Scheduling Conferences, and Initial Disclosures.
· Drafting and responding to ESI discovery.
· Producing responsive ESI documents.
· Providing expert reports and testimony as needed to establish scope and defensibility of discovery efforts.
Clay Rankin E-Discovery Background
· Lead trial counsel for parties in e-discovery negotiations and Rule 37 disputes
· Lead trial counsel in large commercial and maritime litigation 1980-2025.
· ESI consultant for Special Master in USDC.
· ESI mediator Circuit Court of Baldwin County, Alabama.
· Web Developer of electronically stored information (“ESI”) document management systems.
· Provider of web-based ESI search and storage technology
· Author and speaker on e-discovery, e.g. What Every Litigator Needs to Know about Using Web-Based Electronic Document Review Services, The Alabama Lawyer January 2014
· · Owner of Patent US-11663542-B2 Electronic Knowledge Creation and Management Visual Transformation Tool
