Discovery Special Master

• Appointed by court to resolve protective order issues
• Appointed by court to resolve various discovery motion disputes
• Appointed by court to manage discovery process
• Appointed by court to make recommendations on motion for discovery sanctions

Discovery Mediation

• Retained to assist parties with designing a proportional discovery plan
• Retained to assist parties and courts in resolving discovery disputes
• Retained to provide parties with alternative and more effective means to conduct discovery

General Civil Mediation

• Mediated business and contract disputes involving loan agreements, automobile purchases, arrangement between sports complex and travel coach and team, arrangement for sharing office reception area and services between medical professionals and claims against self-storage facility for breach of contract and theft
• Mediated residential and commercial landlord-tenant disputes, including evictions, breach of lease or co-signor agreement and damage recovery actions
• Mediated homeowner claims, including claims against home improvement companies, a home inspection company and fire and water damage restoration companies
• Mediated federal prisoner civil rights litigation cases
• Mediated claims filed under the Agricultural Workers Protection Act

Litigation

• Lead counsel for the Fair Housing Center of Southwest Michigan obtaining a settlement providing three years of court enforced injunctive relief, monetary damages and an award of $241,000 in attorneys’ fees
• Co-counsel defending Section 1983 Civil Rights class action challenging the constitutionality of Michigan’s child foster care system
• Co-counsel for Pharmacia & Upjohn Company obtaining summary judgment in cases alleging discrimination and wrongful termination
• Co-counsel for a prescription drug manufacturer defending price-fixing claims by a putative national class of drug retailers
• Lead counsel obtaining favorable judgment at trial in case involving neighbors seeking tear down of a multi-million dollar home on Lake Michigan for alleged violations of subdivision deed restrictions, local ordinances and MDEQ requirements

eDiscovery and Discovery Management

• Drafted and/or negotiated over 50 discovery plans involving the preservation, collection and review of electronically stored data
• Created and supervised discovery management teams at two AMLAW 200 Michigan law firms
• National discovery counsel for Fortune Global 500 manufacturer; developed and maintained systems for timely and accurate discovery compliance throughout the United States
• National defense counsel for a global pharmaceutical company in price-fixing class actions in 15 U.S. states; developed a litigation and discovery management system for 6,900 plaintiffs, 100 complaints and over 1 million discovery documents
• Appointed as a Special Assistant Attorney General in a federal court civil rights action; designed, implemented and defended a discovery plan that involved the collection of over 1 million pages from multiple locations; briefed and argued motion for protective order, resulting in a 90% reduction in discovery compliance costs
• Local defense counsel for a Fortune Global 100 company in a federal court action involving antitrust and copyright infringement claims; collected, reviewed and produced over 80 million pages of discovery documents
• Discovery counsel for a major professional services firm in response to DOJ grand jury subpoena involving an alleged illegal off-shore tax shelter; designed and implemented hard copy and e-data preservation and collection strategy and created 300 page privilege log involving complex and multi-client communications
• Counsel for a group of furniture manufacturers participating at several landfill Superfund sites; developed a data management system for the review and analysis of documents and deposition testimony regarding manufacturers’ potential liability share; utilized data management system to successfully challenge U.S. EPA’s database and reduce client manufacturers’ share of Superfund liability
• Negotiated sneak peek and clawback arrangement for DOJ’s investigation of government officials as means to reduce time and cost for subpoena compliance