Litigants Fail to Heed Lessons of 'Victor Stanley'
In *Victor Stanley*, the defendants conducted their privilege review using
about 70 different keyword search terms. Defendants manually reviewed those
documents returned in the keyword search. As to the remainder of the
documents, however, defendants took no steps to assess whether the searches
had captured all privileged documents. The result was that defendants
inadvertently produced 165 privileged electronic documents.
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