Law & Forensics designed a defensible data-map, slashed a 14-million-document review population to under 400,000 responsive records, and provided expert testimony that drove early dismissal of the lead plaintiff's core claims.
The situation
A top-5 U.S. property and casualty insurer learned that a third-party claims-processing vendor had suffered a network intrusion exposing the personal information — names, Social Security numbers, policy details, and payment data — of approximately 2.3 million policyholders. Within weeks, plaintiffs' firms in seven states had consolidated a class action alleging negligent data governance, failure to implement reasonable security measures, and breach of contract.
Discovery demands were broad by design. Plaintiffs sought eight years of communications and documents across underwriting, claims, IT operations, and vendor management — a universe estimated by the carrier's existing review vendor at 14 million documents and an eDiscovery spend in excess of $9 million. Compounding the challenge: the carrier's data was distributed across aging on-premises document-management systems, two acquired-company legacy platforms, and three current cloud environments, none of which shared common metadata schemas.
Our approach
Law & Forensics engaged at the outset of litigation, before any processing or review began, to redesign the discovery approach from the ground up.
Forensic data mapping. The team conducted a comprehensive enterprise data-map across all eight custodial and non-custodial source environments, identifying where responsive data could plausibly reside, where it demonstrably could not, and where legal hold obligations attached. The mapping exercise produced a court-ready data-landscape declaration that withstood plaintiffs' challenge at the Rule 26(f) conference.
Early case assessment and targeted culling. Using forensic collection protocols tailored to each source platform, Law & Forensics applied date-range filtering, domain exclusions, deduplication, and concept clustering before a single document entered the review platform. The 14-million-document population was reduced to approximately 390,000 documents for attorney review — a 97% reduction that held up to opposing counsel's proportionality scrutiny.
Expert testimony on reasonable security. A Law & Forensics senior examiner served as the carrier's testifying expert on data-governance practices and vendor-oversight controls. The expert report documented the carrier's security program against NIST CSF and applicable state insurance-security regulations, establishing that the carrier had implemented industry-standard controls and that the breach originated entirely within the vendor's environment.
The impact
The defensible culling methodology reduced eDiscovery spend by approximately 60% against the original vendor estimate — saving the carrier an estimated $5 million in review costs alone. Expert testimony on the carrier's reasonable security posture contributed directly to the court's grant of summary judgment on three of the four lead claims, including the data-mismanagement theory that underpinned the class's damages model. The matter resolved within 18 months of filing.
| Metric | Result |
|---|---|
| Reduction in review population | 97% (14M → 390K documents) |
| eDiscovery cost savings vs. initial estimate | ~60% |
| Lead claims dismissed at summary judgment | 3 of 4 |
| Time to matter resolution | 18 months |
