the importance of properly crafted electronic searches
In a recent case, Magistrate Judge Peck elucidated the proper procedure for devising search keywords:
1) there must be cooperation between opposing counsel. Therefore, he strongly endorsed The Sedona Conference Cooperation Proclamation; 2) attorneys must carefully design the appropriate keywords; 3) keywords should be selected with the input from the ESI’s custodians; 4) Finally, the proposed technique should be validated to ensure it is not substantially over- or underinclusive.
* William A. Gross Constr. Assocs., Inc. v. American Mfrs. Mut. Ins. Co.