Your Litigation Response Plan should include culling and filtering strategies. Review is by far the most expensive part of Electronic Discovery. You can save a fantastic amount of money by culling or filtering the data population, but the culling must be defensible and the strategies must be sound.

Lawyers tend to immediately glob onto keywords and phrases as a way to search or filter data, but there are some other methods that work well, especially before keyword searches. For example, in another video we talked about file types. In most cases, you don't need to look at Window system files or program files. Often multimedia files, such as sound or video files, are not necessary except for certain types of legal matters such as intellectual property cases. So you may want to cull by file type first. You may also cull or filter by person, a person's computer, mailbox, date ranges, and geographical area. Then cull further by keyword searches and phrases to reduce the data population.

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