Representative matters
Organized by the dispute, not the industry.
Selected discovery referee, special master, and forensic neutral appointments, grouped by the kind of discovery dispute resolved. Engagement of Daniel Garrie as a neutral is administered through JAMS.
01 — Special Master & Discovery Referee
Court-appointed management of discovery.
Court-appointed management of discovery in federal and state litigation — setting protocols, hearing disputes, and reporting to the court.
02 — Forensic Neutral
Inspection and imaging protocols.
Designing and supervising inspection and imaging protocols — giving the requesting party meaningful discovery while protecting privilege, privacy, and trade secrets.
03 — Spoliation & ESI Protocol
Preservation failures and production protocols.
Preservation failures and the protocols that govern production — separating genuine loss from ordinary system behavior, and resolving the protocol before it hardens into a motion.
04 — Trade Secret & Forensic Inspection
Access disputes over sensitive systems.
Access disputes where the evidence lives on the other side's systems — balancing the need for inspection against the protection of competitively sensitive material.
05 — Cybersecurity, Privacy & Data Breach
Disputes over how data was held or exposed.
Disputes turning on how data was held, exposed, or compromised — resolved by a neutral who works fluently with security and forensic facts.
06 — Cross-Border
Discovery across jurisdictions.
Discovery spanning jurisdictions and conflicting data regimes — coordinating production across borders and competing legal obligations.
Get the Model Discovery Order Pack — free.
Four adaptable templates — a Rule 53 special-master order, an ESI-protocol mediation clause, a discovery-referee stipulation, and a forensic-inspection protocol — plus a short note when a new insight publishes.
Have a matter that fits one of these?
Request Daniel Garrie by name, or send a short inquiry to discuss the right vehicle. Engagement is administered through JAMS.