Expert Witness · Special Master · Neutral
When ESI is the fight, you need an expert the court already trusts.
Spoliation, proportionality, TAR validation, collection defensibility — most disputes turn on whether a process was reasonable and a record is credible. Daniel B. Garrie has opined on exactly that in more than 100 courts and tribunals.
100+
Courts & tribunals
500+
Opinions & articles citing his work
20+
Years in eDiscovery & forensics
600+
Seminars for judges & counsel
Capabilities
The full ESI lifecycle, opined and defensible.
ESI Collection & Defensibility
Opinions on whether a collection was forensically sound, reproducible, and defensible — or whether it wasn't.
Spoliation & Sanctions — Rule 37(e)
Analysis of preservation failures, intent, prejudice, and the reasonableness of steps taken, for or against sanctions.
Proportionality — Rule 26(b)(1)
Whether discovery demands and objections are proportional to the needs of the case, grounded in the technical reality.
TAR / Predictive Coding Validation
Independent validation of technology-assisted review workflows, metrics, and defensibility.
Review-Process Defensibility
Whether a review process was reasonable and its output credible — the questions most disputes actually turn on.
Expert Reports & Testimony
Daubert-ready reports, rebuttals, and testimony that survive cross-examination in federal court, state court, and arbitration.
Why retain
Built to win the technical fight.
Court-appointed and court-tested
Regularly the person courts appoint as Special Master to referee these disputes — which is why party-retained opinions carry weight.
Engineer and attorney
A computer scientist and a lawyer, fluent in both the technology and the rules that govern it.
Translator for the trier of fact
Complex ESI questions explained so a judge or jury can follow the reasoning and trust the conclusion.
Responsive under deadline
Reports, rebuttals, and testimony delivered on the timelines litigation actually runs on.
What does an eDiscovery expert witness actually do?+
An eDiscovery expert opines on whether an electronic-discovery process was reasonable and whether a record is credible — spoliation and sanctions under Rule 37(e), proportionality under Rule 26(b)(1), collection defensibility, and the validation of technology-assisted review. The work product is expert reports, rebuttals, and testimony that survive Daubert and cross-examination.
When should we retain an expert?+
The most expensive eDiscovery mistakes are baked in at the planning stage. Retaining early — before a disputed collection or a spoliation allegation hardens — is far more effective than retaining after. That said, engagements frequently begin mid-dispute, on deadline.
What is the difference between an expert and a Special Master?+
A retained expert works for a party and opines on that party's behalf. A Special Master or neutral is appointed by the court to referee discovery for all parties. Daniel Garrie serves in both capacities, which is precisely why his party-retained opinions carry weight — he is regularly the person courts trust to referee these disputes.
How do you ensure an opinion survives a Daubert challenge?+
By grounding every opinion in a documented, reproducible methodology, a clear chain of reasoning the trier of fact can follow, and a record that withstands scrutiny. Ask for a prior redacted report and deposition testimony — the work should speak for itself.
What types of matters do you handle?+
Data-privacy class actions, discovery disputes, spoliation and sanctions motions, TAR and predictive-coding validation, collection defensibility, and data-breach matters — in federal court, state court, and arbitration, nationwide.
Engage
The deadline is real. So is the technical fight.
Send the matter name, jurisdiction, and key dates. You'll receive a prompt conflict check and a scoping conversation.