Applying Custom Digital Technology to a 20 Year Old Warehouse of Paper

The company faced an employee class action suit with 100 named plaintiffs, which required collection of more than 7,000 boxes of paper files that spanned twenty years of company history.

Client Challenge

The litigation discovery required production of records and files related to the 100 named plaintiffs. The client identified 7,000 boxes of paper documents spanning a twenty-year period—an estimated 15 to 20 million pages—which needed to be indexed, searched for responsive content, and potentially produced.

Consilio structured the project to accomplish two goals:

  • Search the boxes and identify documents pertaining to the 100 employee plaintiffs.
  • Index the contents of all boxes for effective records management going forward.

Consilio Response

Consilio secured and prepared warehouse space to store and organize the 7,000 boxes, adjacent to a work area built out to accommodate a team of more than 100 document reviewers. We then designed and implemented a workflow that involved both physical and digital efforts.

  • First the boxes were evaluated by content and type. Our office administration team procured a massive quantity of supplies, including 175,000 file folders and more than 100,000 labels, to sort, organize, and label contents of the boxes and paper files.
  • Using Relativity dynamic objects, our analytics team created a custom application to support data entry, which included built-in controls for data quality, validation, and consistency. Once the key data elements were added to a review database, the application enabled indexing of the files, with indexes allowing search by folder, box, employee, pallet, and class member level. The indexes related to each other to give users full details about folder location and content. The index served as a ‘card catalog’ of sorts, supporting search and retrieval of paper files and documents.
  • A menu of standard reports was created, allowing users to easily generate reports to manage the project and check status on progress.

Results Achieved

Reduction in manual review effort: When it became apparent that manual review of all boxes would require more resources than available in the allowed time-frame and budget, Consilio innovated a solution. Using statistical sampling, the team produced a report that analyzed the likelihood of finding relevant plaintiff information. This allowed the client to successfully argue to the court that not all boxes needed to be fully reviewed, significantly reducing time and cost of review.

  • Increased precision in records management: The indexing and tracking system designed for the project was precise enough to find five random ‘outlier’ boxes—out of 7,000— that the client had accidentally shipped to the review site.
  • The client was delighted at the innovative use of analytics tools to bring efficiency and cost savings to a daunting paper review project.
  • The solution was so appreciated by the client that they have continued to call upon Consilio to partner on similar eDiscovery review matters.

Company Profile

A global corporation that operates retail, grocery, and online stores.

Services Utilized