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ACEDS Webinar: Responding to Second Requests – There’s a Better Way
November 3, 2022 @ 12:00 pm - 1:00 pm

Webinar: Responding to Second Requests – There’s a Better Way
Date: Thursday, November 3, 2022
Time: 12:00pm CST/ 1:00pm EST
Register: Click Here to Register
In the name of the “unique nature” of a Second Request review, experienced practitioners often maintain that only traditional review protocols will work, and unhesitatingly accept a production set that may be upwards of 50% nonresponsive. But as Jeff Bezos (Amazon) observed in a 2016 letter to shareholders: Day Two is stasis. Followed by excruciating, painful decline. Followed by death. And that is why it is always Day One.
Join OpenText principal consultants Tom Gricks and Tracy Drynan as they discuss the need to strive to continuously live Day One, and prioritize focused innovation over tradition to find better ways to respond to Antitrust Second Requests. Topics include:
- The shortcomings of traditional techniques used to respond to Second Requests
- Best practices for overcoming DOJ/FTC objections and constraints on review techniques that leverage technology or software to identify or eliminate data
- Rapid analytic investigative review as an alternative technique and the associated benefits
Sponsored by:

Sr. Principal Consultant
OpenText
Tom is a prominent eDiscovery attorney, leading authority on the use of TAR for litigation and investigations, and eDiscovery Special Master. Tom advises clients on how to optimize machine learning and analytics techniques on investigations, has developed the managed review program for internal, compliance and regulatory investigations, and develops investigation-specific applications and TAR protocols. He brings more than 30 years’ legal and eDiscovery expertise to clients.

Principal Consultant
OpenText
Tracy leads the Recon Investigation team at OpenText™. She has extensive experience across the eDiscovery lifecycle, including 12 years conducting and managing investigations, interpreting Requests for Information and Complaints to identify sources of relevant information, developing strategies for targeting and gathering data, performing custodial interviews, and managing information collection. Prior to joining OpenText, Tracy was a senior attorney with Drinker Biddle & Reath LLP.
Hosted by ACEDS | 03 Nov 2022 @ 12:00pm CST
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