Expertise Antitrust Litigation, Financial Disputes, Financial Litigation, Medical Device, Medical Patent Infringement litigation, Project Management, Project Manager
Jeremy Ballew Project Manager - Dallas, TX
Jeremy Ballew joined Special Counsel as a Project Manager in 2011. Jeremy has extensive experience with complex antitrust litigation, financial disputes, and medical patent Infringement litigation. His most recent antitrust project involved every facet of the discovery phase for a large second request. This year-long project required a team of more than 150 attorneys during two separate phases of the investigation. In addition to project management, he has worked intimately with trial counsel in the attack and defense of dueling Motions to Compel related to massive privilege logs. Jeremy received his Juris Doctor and Master of Laws in Taxation from Southern Methodist University. He also earned a Bachelor of Arts in History from the University of South Carolina. Jeremy is a member in good standing of the State Bar of Texas.
Jeremy has an excellent record of remotely managing teams of attorneys located in Special Counsel’s national review centers. One recent project exemplifies this record. The client was faced with a short deadline. Counsel utilized predictive coding to cull the dataset to a manageable number. A team of six reviewers was pulled together in Minneapolis. Jeremy remained in Dallas and closely supervised all of the tasks performed by the team.
The team was asked to conduct a privilege review of the documents with a relevancy score of 76 or greater. In addition, the team reviewed a statistical sample of the documents with a relevancy score below 75. The initial review set was based on a limited privilege term set. In order to increase the speed of the review and the accuracy of the calls, Jeremy created a comprehensive persistent highlighting scheme that was continuously updated as additional attorneys were identified in the documents.
Through the efforts of the review team, the list of attorneys more than doubled in size. Jeremy then created targeted searches against the responsive and not privileged set for documents that hit on the newly identified terms. These additional efforts ensured that privileged material was not inadvertently produced. Due to counsel’s aggressive stance on privilege, Jeremy recommended the creation of a “borderline privilege” tag to be used as a backstop to mitigate the risk of reviewers being too aggressive with de-designation calls. This tag allowed counsel to quickly make calls on only a small subset of marginally privileged documents, as opposed to having to run exhaustive searches on the entire review population searching for missed privilege.
During counsel’s review of a sample of Special Counsel’s work, they identified a number of categories of documents that were included in the production set due to predictive coding issues. Special Counsel quickly mobilized the team to conduct a fast-paced quality control of the production set for these and other non-responsive categories. In only a few hours, the team was able to pull a significant portion of non-responsive documents from the production set without jeopardizing the production deadline. Jeremy recommended several options to counsel regarding the preparation of the privilege log. By addressing shortcomings with the database early on, he was able to put in place workarounds at the onset of the logging phase. The team utilized several cost-effective processes to expedite the creation of the privilege log and delivered two versions of the log to counsel, so they could make a decision on which route they wanted to take. Even with preparing two versions of the log, the team completed the logging phase well ahead of schedule.