David S.
Vandiver III

Serving as project manager, supervising and managing six separate document collections, reviews, and productions over the past three years for an international financial services provider.  These matters involve claims based in securities, bankruptcy, and commercial litigation and investigations by governmental agencies.  These matters involved all aspects of discovery ranging from an onsite hard copy document collection from more than 1,400 archive records boxes to the online review of more than 500,000 electronic records for production to regulatory and oversight agencies including the SEC, FDIC, PCAOB, and FINRA.   

Managing and supervising 20 attorneys reviewing more than 400,000 documents for a large financial institution in response to regulators’ requests for documents relating to short-term, money market funds.  This project involved reviewing documents for responsiveness, significance and privilege.  All documents were reviewed, and responsive documents produced in less than 10 weeks.  The review team also logged over 4,000 privileged documents.

Managing 7 attorneys reviewing 10,000 documents for a financial institution, including review of credit and collateral files for accounting issues in preparation for witness interviews in a shareholder derivative lawsuit.  This review was completed in less than two weeks. 

Managing and supervising 7 attorneys reviewing 65,000 documents for a financial services company for a federal regulatory matter.  

Managing 10 attorneys reviewing 120,000 documents related to federal regulators’ investigations involving an international banking and financial services firm.

Coordinating with litigation technology support staff and a team of 6 attorneys to review over 12,000 documents in response to a federal regulators’ third-party subpoena regarding the accounting practices of a large manufacturing client’s retail customer.  This included developing and utilizing search term strategies that resulted in the elimination from the review of approximately 40,000 non-relevant, previously collected documents, providing substantial savings for the client.  Over 3,000 responsive documents were produced electronically in compliance with the agency’s published, precise formatting criteria for produced documents.

Managing and training as many as 88 attorneys, 10 paralegals, 15 project assistants and 6 IT professionals in connection with a review of more than 4 million documents.  Documents were reviewed for responsiveness, privilege, confidentiality, and significance to discovery requests in both federal and state courts throughout the country over a 3-year period.  

Supervising a team of as many as 50 attorneys, paralegals, project assistants and IT professionals reviewing over 2.6 million documents over a 5-year period for a Fortune 50 consumer product client involved in litigation in federal and state courts throughout the country, producing over 1.8 million documents in paper copy and electronic format, and making available over 1.2 million documents to a settlement-mandated, out-of-state centralized document depository.  Drafting proposals, protocols and record-keeping forms for large scale, company-wide document collection and interviewing and supervising the interview of over 800 company personnel, including senior officers and directors, so as to ensure collection of documents most likely to be relevant to the litigation and substantial cost savings to a large pharmaceutical client involved in product liability litigation throughout the country.

Supervising a team of 30 attorneys in the preparation of a privilege log consisting of over 20,000 documents for a Fortune 100 consumer products client in environmental litigation. 

Managing and training a team of 10 attorneys in the review of over 175,000 documents in a patent infringement lawsuit for an internet security and services client.  The documents were reviewed for privilege, significance and responsiveness; the review was completed in less than 6 weeks.

Supervising and managing large scale collection of more than 2.5 million documents in diverse locations (e.g., client headquarters and sales, manufacturing and other offices) for a large consumer product client in complex, mass tort, and product liability litigation in both federal and state courts throughout the country.

Managing multiple third-party vendors responsible for all phases of document collection and processing, including photocopying, imaging, and objectively coding millions of documents.  This included developing a coordinated plan with a vendor’s national and regional offices to oversee nationwide document collections over a 6 month period.

Advising a real estate investment trust on document retention and collection policies and coordinating a document collection from 25 corporate personnel for documents responsive to two shareholder lawsuits.

Coordinating document discovery issues (e.g., document collections, document productions, deposition preparation, and privilege logs) with national co-counsel and local trial counsel involved in multi-jurisdictional litigation throughout the country.

Litigation Technology Experience

Through his significant involvement in training and supervising attorney review teams, as well as his experience collecting, processing, and producing documents, Mr. Vandiver regularly participates in the selection and supervision of vendors.  He also has experience drafting and developing review team plans and protocols.  He has extensive experience with litigation support systems including Relativity, Stratify, ClarVergence, Ontrack Inview, Attenex, IConect, Introspect, Discovery Radar, Concordance, IPro, Microsoft Excel, and Microsoft Access.