Law & Forensics · eDiscovery Playbook®
Your next lawsuit is already in your data.
The chaos is optional. The eDiscovery Playbook® is the defensible operating manual for legal hold, collection, review, and production — written by the expert courts appoint to referee these exact disputes.
- Role
- Expert · Special Master · Neutral
- Forum
- Federal · State · Arbitration
- Standard
- Rule 26 · Rule 37(e) · Daubert
- Output
- A record that holds up
Active matter?
855-529-2466100+
Courts & tribunals
500+
Opinions & articles citing his work
20+
Years in eDiscovery & forensics
600+
Seminars for judges & counsel
Appointed, published, and recognized by
The stakes
Discovery is where cases are won, lost, and sanctioned.
Review consumes the majority of most litigation budgets. Courts now hold parties to the ESI protocols they negotiated — and sanction the ones who cannot show a defensible process. The most expensive mistakes are baked in at the planning stage, long before anyone files a motion.
Most organizations meet their eDiscovery strategy for the first time at the meet-and-confer — improvising preservation, guessing at data sources, and hoping the collection holds. The eDiscovery Playbook® replaces improvisation with a documented, repeatable, defensible process you build before the complaint arrives.
The flagship engagement
The eDiscovery Playbook®
A living operating manual that aligns Legal, IT, Privacy, Records, and HR around the same defensible steps — ten elements, one named owner each, all built to the standard courts actually apply.
Legal-hold triggers & issuance
Written criteria for when the duty to preserve attaches, plus the hold-notice workflow, custodian acknowledgment, and auto-deletion suspension that make it defensible.
Custodian interviews & data mapping
A repeatable interview protocol and a living map of where responsive ESI actually lives — email, chat, mobile, cloud, and the systems people forget.
Preservation procedures
Step-by-step preservation across modern data sources, with the documentation that survives a Rule 37(e) challenge.
Modern data sources
Microsoft 365, Teams, Slack, Google Workspace, mobile, and ephemeral messaging — captured, not overlooked, when the hold lands.
Collection & chain of custody
Defensible collection methods and an unbroken chain of custody that an opposing expert cannot pull apart on cross.
TAR / CAL / AI review workflows
Validated technology-assisted review protocols — the workflow, the metrics, and the validation record that hold up when challenged.
Production specifications
Format, metadata, and privilege-handling specs negotiated to protect the client and to be enforceable against the other side.
Rule 26(f) & 37(e) ESI protocols
Meet-and-confer-ready protocol templates — the terms courts now hold parties to, drafted by the person courts appoint to referee them.
Roles & responsibilities
A named owner for every step across Legal, IT, Privacy, Records, and HR, so nothing falls through the gap between departments.
Disposition at matter close
Defensible disposition when the matter ends — closing the loop without creating the next spoliation exposure.
The path
From improvisation to a defensible record, in four steps.
Readiness Scorecard
A 2-minute self-assessment that grades your current eDiscovery posture and shows where the exposure sits. Free.
Complimentary Playbook Review
A working conversation with the expert team to pressure-test your assessment and scope what a defensible playbook requires.
Fixed-Fee Gap Assessment
A scoped diagnostic of your preservation, collection, and review practices against the standard courts apply — with a prioritized remediation plan.
Scoped Playbook Buildout
We build your eDiscovery Playbook® — the operating manual your Legal, IT, and Privacy teams run from, ready to defend.
Who we serve
General Counsel
Defensibility, budget predictability, and something concrete to show the board.
Litigation Partners
A client discovery process that survives the meet-and-confer and the sanctions motion.
CISOs & Legal Ops
Legal hold, data mapping, and preservation that actually work when litigation hits.
Why the Playbook holds up
Built by the expert courts appoint when eDiscovery goes wrong.
Daniel B. Garrie has served as Special Master and neutral in more than 100 courts and tribunals, co-authored guidance for the Federal Judicial Center with sitting judges, and had his work cited in over 500 opinions and articles. When your process is challenged, the playbook was written by the person on the other side of that appointment.
N.D. Cal. · MDL
In re: Facebook Consumer Privacy User Profile Litigation
Court-Appointed Special Master
JAMS · Arbitration
Washington Commanders v. NFL
JAMS Neutral
N.D. Cal. · Federal
United States v. Joseph Sullivan
Subject-Matter Authority
Federal & State
eDiscovery Special Master appointments
Special Master · Referee
On the record
What retaining counsel say.
“He is the person you want writing the protocol you will have to defend two years later. Nothing in his work product gives the other side a foothold.”
“We stopped treating eDiscovery as a fire drill. The playbook gave our board something concrete to see and our outside counsel something they could rely on.”
“When the judge appoints the same expert other courts appoint as Special Master, the credibility problem solves itself.”
“The readiness assessment found gaps we genuinely did not know we had — in preservation and in our messaging-app data. Fixing them before a matter beat finding out during one.”
“Our review costs became predictable for the first time. The playbook made discovery a process we run, not a crisis we survive.”
“He explains the technology so a jury follows it and an opposing expert can't muddy it. That is rarer than it sounds.”
Common questions
Before you engage.
What is the eDiscovery Playbook®?+
It is a proprietary, court-tested operating manual that defines your organization's repeatable, defensible approach to electronically stored information — from legal-hold triggers through collection, review, production, and disposition — with a named owner for every step. eDiscovery Playbook® is a trademark of Law & Forensics; it is a structured engagement built and supervised by a court-appointed expert, not a generic template.
How is this different from the free "playbook" PDFs vendors give away?+
Those are marketing collateral. The eDiscovery Playbook® is a scoped consulting engagement that produces a defensible operating manual specific to your data, your systems, and your litigation profile — authored under the supervision of the expert courts appoint to referee these exact disputes. It is built to hold up when an opposing party challenges your process, not to be downloaded and forgotten.
Who buys an eDiscovery Playbook® engagement?+
General counsel and legal-ops leaders who want defensibility and budget predictability; litigation partners who need a client's discovery process to survive the meet-and-confer and the sanctions motion; and CISOs and IT leaders responsible for legal hold, data mapping, and preservation that actually works when litigation hits.
What does an engagement look like?+
It typically follows four phases: a free readiness scorecard, a complimentary playbook review, a fixed-fee gap assessment, and a scoped buildout of the playbook itself. Engagements are fixed-fee and scoped to your organization's litigation profile.
Will the playbook hold up in court?+
That is the entire point. It is built to the standard courts apply under Rules 26 and 37(e), by an expert who has served as Special Master and neutral in federal and state courts and whose work is cited in more than 500 opinions and articles. The playbook is designed so that when your process is challenged, the record is already made.
How do conflicts and engagement work?+
Every inquiry is subject to a conflicts check and a written engagement agreement. Send the organization name and a short description of your situation, and you will receive a conflict check and scoping response within one business day.
Engage
Your next lawsuit is already in your data.
The chaos is optional. Build the playbook before the complaint — or bring in the expert courts appoint when discovery goes wrong.