Jim’s practice focuses on discovery management, providing critical document review as well as advice on privilege issues and document retention. He has worked on multiple high-profile cases involving multimillion-page production or review in several industries, including pharmaceutical, food, medical device, tobacco, construction, hazardous waste, advertising and insurance. His cases have involved product liability, breach of contract, breach of warranty, patent and trademark disputes as well as domestic and international regulatory and governmental investigations.
Among the project areas Jim manages for ongoing litigation are:
- Establishing practical and cost-effective management of privilege review;
- Drafting and commenting on privilege review guidelines and protocol;
- Managing privilege review teams; drafting, reviewing and finalizing privilege logs (domestic and international); and
- Advising case teams on attorney-client privilege, work product doctrine and joint defense privilege.
- Reviewing material for responsiveness, confidentiality, privilege and proprietary information; coordinating and supporting document reviews with outside counsel and third-party review vendors;
- Analyzing client documents and testimony for issues relevant to claims, defenses and witness preparation;
- Assisting in the drafting of legal hold notices, scope of review statements, protective orders, discovery plans and joint defense agreements; and
- Advising on retention policies and the defensible destruction of documents and electronically-stored information (ESI).
- Collecting client documents (domestic and international);
- Supporting case teams in drafting golden rule letters, meet and confers, and responses to motions to compel; and
- Drafting responses to written discovery requests.
Schmedding v. Tnemec Co, 187 F3d. 862 (8th Cir. 1999)
In Re L.C.F., 987 S.W.2d 830 (Mo App. W.D. 1999)
Payne v. Weker, 917 S.W.2d 201 (Mo App. W.D. 1996)