Jonathan Redgrave has called my attention to an excellent article which he co-authored by Judge Shira Scheindlin focusing on the benefits that may be obtained by generous use of special masters in connection with e-discovery. The article, entitled "Special Masters and E-Discovery: The Intersection of Two Recent Revisions to the Federal Rules of Civil Procedure", appears at 30:2 Cardozo L. Rev. 347. The article includes sample orders appointing special masters.
The authors suggest that "[t]he appointment of a special master may make it possible to accomplish in days what would otherwise consume months of litigation and require both sides to incur substantial costs." They further point out that appointment of the right special master will actually save the parties money in the long run, notwithstanding the fees and expense of the special master.
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