Chris focuses his practice on discovery issues in securities and product liability cases, with a particular emphasis on document production. He is experienced in exhibit admissibility as well as document privilege and confidentiality issues. Chris has worked on projects ranging in size from several hundred pages to multimillion-page production and review, often in high-profile, bet-the-company cases.
- Drafting (and/or commenting on drafts of) privilege review guidelines and protocol;
- Reviewing material for responsiveness, confidentiality, privilege and proprietary information;
- Managing privilege review teams;
- Drafting, reviewing and finalizing privilege logs (domestic and international);
- Advising case teams on attorney-client privilege, work product doctrine and joint defense privilege;
- Drafting responses to written discovery requests;
- Analyzing client documents and testimony for issue relevant to claims, defenses and witness preparation;
- Analyzing and reviewing exhibit lists in multidefendant litigation for issues relevant to claims, defenses, privilege issues, witness preparation and frequent trial objections; and
- Analyzing and reviewing plaintiffs’ deposition designations for issues relevant to claims, defenses, privilege issues, witness preparation and frequent trial objections.