Case Study – Reduce and produce 540,000 relevant documents within 3 weeks to save millions in potential late fees.


From 7 million to 540,000 relevant documents reviewed in 3 weeks to save a client millions of dollars in potential late fees.

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A leading healthcare manufacturer, distributor and solutions provider of medical supplies and solutions focused on improving the overall operating performance of healthcare.

  • AM Law 100 firm
  • Chicago, IL law firm
  • Discovery special master

Since 2019, CLIENT became the defendant of multiple lawsuits claiming that ethylene oxide, the chemical the company used to sterilize their medical equipment, was a carcinogen that caused cancer to some people who were exposed to ethylene oxide released into the air during the sterilization process.

Originally tried as a class action suit, multiple cases were subsequently moved to individual courts to account for variances specific to each case. As the defendant, CLIENT claimed that there was not sufficient evidence to directly implicate them in the cases. Despite having completed the discovery process, one plaintiff claimed the case / discovery process was tainted. The courts agreed, with Discovery Special Master requiring CLIENT to conduct a deeper discovery process to substantiate their claims, much to the company’s chagrin.


The client followed and complied with all requirements of the judge and opposing party requests until appointment of Discovery Special Master. The special master’s last-minute voluminous requests substantially burdened the client with a nearly impossible discovery project deadline. As defending attorneys, Counsel contacted Intrepid Managed Discovery to take the lead on orchestrating the document review to avoid incurring astronomical penalties if documents were produced post deadline.

  • Cull 7 million document data set to manageable review set
  • 3-week timeline to review and produce
  • 3-days to prepare for court

Inspired by the daunting task at hand, Intrepid Managed Discovery took immediate action employing an aggressive strategy to meet the deadline. Within 3 days over a weekend, Intrepid assembled a 100+ person managed review team to examine documents with responsive term hits to expedite the review without missing pertinent details. Documents were divided into different subsets pre-marked as privileged, non-responsive, etc. to categorize and further prioritize the review.


As required by Counsel and the courts, Intrepid Managed Discovery directed the 100+ person review team to successfully complete the challenging project 2 days before the deadline.

  • Staffed 100+ review attorneys
  • Developed an agile, aggressive review strategy
  • Culled 7 million documents to 540,000 reduced data set
  • Reviewed and produced 540,000 relevant documents
  • Enabled sufficient time for quality control
  • Enabled sufficient time for final productions and trial preparation

In collaboration with Discovery Special Master on behalf of Counsel, Intrepid Managed Discovery provided a potent blend of relentless grit, precision strategy and collaborative communications to exceed aggressive client (and court) expectations in support of the defendant’s case.