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Mark Wauck's avatar

OK, that was THREE things, and CONSTANT.

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Anne Sherman's avatar

Re: the 500 pages per month - an experienced document reviewer can read, analyze, code and redact more than 500 pages per DAY, particularly given the sophistication of electronic document review software and the fact that many of these documents are probably email chains with or without attachments. A redaction in the original email will carry over to every iteration of that email in the chain, as well as the coding and any attorney analysis notes. All the reviewer then has to do is code the subsequent emails in the chain and modify the coding and add to the attorney notes if necessary, which are both carried over just as in the original document. For over a decade, I developed litigation strategy on mass tort cases employing large numbers of document reviewers and know this subject intimately. The FDA protestations are rank BS, unless the documents are handwritten and must be reviewed individually.

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