The challenge.
A $60B life-sciences merger drew an HSR second request 14 days after filing. The acquirer’s outside counsel — a top-three AmLaw firm — needed a full-coverage document review operational in under three weeks, including responsive coding, privilege screening, and an audit trail their own QC team could verify before production.
The constraints:
- 2.4M documents across 14 custodians, mixed business and personal communications
- 15-week production deadline from second-request issuance
- Two foreign-language tranches (Spanish, Portuguese) requiring native review
- Sealed environment — engagement under MNDA with named-only access
- Three privilege tiers: outside counsel, in-house, and regulatory privilege
The client had pre-cleared two other vendors. Both quoted 18+ days to ramp and declined to commit on production date. We took the engagement.
Our approach.
Three things determined the outcome: bench depth, parallel onboarding, and senior PM ownership from day one.
Bench depth
The 280-reviewer team came entirely from our pre-vetted pool — no postings, no résumé screening, no bar verification delay. Every reviewer had cleared our five-stage vetting before being eligible for the matter. The Spanish and Portuguese tranches came from our Tier-1 multilingual bench.
Parallel onboarding
Instead of cohorting 280 reviewers through a sequential onboarding pipeline, we ran three parallel onboarding tracks staffed by separate team-lead pods. New reviewers were billable within 24 hours of clearing onboarding.
Senior PM ownership
The PM on the matter had run 22 prior second requests over 14 years. Protocol design happened in parallel with reviewer onboarding, not after — so day-one reviewers had a finalized protocol in hand, not a draft.
Staffing model.
- 1 lead PM + 2 supporting PMs (one per shift on continuous coverage)
- 11 team leads at a 1:25 lead-to-reviewer ratio
- 280 first-pass reviewers, including 22 Spanish-fluent and 14 Portuguese-fluent
- 16 dedicated QC reviewers running stratified sample passes
- 4 privilege specialists handling Tier-2 and Tier-3 privilege escalations
- Coverage: 18 hours/day, 6 days/week, US East + US Mountain + EMEA partner shifts
Protocol & QC.
We ran the standard three-pass QC model with a heavier privilege overlay given the matter’s sensitivity.
- Pass 1: 100% reviewer coverage, responsive coding + four-level privilege call
- Pass 2: 12% stratified sample re-reviewed by team leads (vs. our 10% default)
- Pass 3: 3% senior QC sample (vs. 2% default), with priv-specialist escalation
- Pre-production sweep: 100% re-review of any docs coded “privilege Tier 3” or “responsive-but-sensitive”
The outcome.
Production delivered 11 days ahead of regulatory deadline. Zero post-production claw-backs. The QC trail (full audit report, protocol-by-protocol agreement metrics, reviewer-level accuracy distributions) was furnished to the antitrust review team as part of production.
- 2,400,000 documents reviewed against the responsive protocol
- 411,200 documents coded responsive
- 18,400 documents withheld on privilege (3.2% privilege withhold rate)
- 99.6% privilege recall measured against the pre-production sweep
- 99.4% coding accuracy on Pass 1 vs. Pass 2/3 agreement
- $2.1M under budget at closeout against original fixed-bid
What we’d do again.
Three operational decisions made the difference:
- Parallel onboarding tracks. Three tracks cut effective ramp from 9 days to 4. We’ve made this the default for any deployment over 100 reviewers.
- Privilege overlay on QC. The 100% re-sweep of Tier-3 docs was expensive but produced the audit trail that mattered. Now standard on high-stakes engagements.
- Senior PM on protocol from day zero. Day-one reviewers having a final protocol — not a draft — eliminated the recode cycle that typically eats 5–7% of total review time.