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Discovery Audit & Special Master Service


Litigators understand that a great deal of their time and client's money is directed toward pre-trial discovery. In the exchange of documents, succession of depositions and other pre-trial work, many disagreements over discovery arise between parties. In many cases, busy trial court judges simply cannot resolve complex discovery issues. Without resolution of discovery matters, litigation takes longer, costs more and there is too much uncertainty for the parties to evaluate their case for settlement purposes.

The Center for Legal Solutions' discovery auditing and special master services can help litigatores resolve numerous, complex discovery disputes fairly and efficiently. Parties can submit some or all discovery issues to a neutral discovery auditor or special master who will carefully consider the parties arguments and provide the parties prompt rulings or recommendations that resolve the discovery issues.

For example, the discovery auditor or special master can help the parties:
  • Create a Reasonable Plan for Completing Discovery;
  • Help Parties with Practical Solutions to Discovery Issues;
  • Resolve Issues Related to Electronic Discovery;
  • Rule or Offer Recommendations on Specific Objections;
  • Review Privilege Claims.

How It Works

The discovery auditing process generally follows a series of stages.

Georgia law refers to a neutral who is appointed to help parties resolve facts and issues as an "auditor." O.C.G.A. § 9-7-1 through 9-7-23 governs the use of auditors in cases pending in Georgia's Superior and State Courts.

In federal cases, Federal Rule of Civil Procedure 53 allows parties to use special masters.

The mechanics of referring discovery issues to an auditor or special master are different in state and federal courts. Parties are encouraged to consult state and federal rules for further information on the specific operation and mechanics applicable to their case. We also encourage parties to review our model consent order for referring discovery matters to an auditor or special master.

A discovery auditor or special master may be particularly useful in cases involving electronic discovery issues. We have found that electronic discovery presents issues that are not readily understood by a busy judge hearing a motions calendar. Creative, custom solutions may be required to achieve a reasonable balance between cost and the need for discovery.

How Much It Costs, How Long It Takes

The parties are responsible for the cost of the time their discovery auditor or special master spends working on their case, including time spent before and after any hearings that take place as well as time spend drafting recommendations or rulings. There is no charge for travel to or from hearings at The Center for Legal Solutions or other convenient sites in the Metro Atlanta area.

Our neutrals charge varying rates for their time and you are encouraged to browse individual neutral profiles for rate information. The cost is typically shared equally by the parties.

If you have questions about The Center for Legal Solutions that are not answered on this web site, feel free to e-mail your question to questions@centerforlegalsolutions.org and we will do our best to respond within 48 hours.

Barry Edwards An ADR Process to Effectively Resolve Discovery Disputes
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The Center for Legal Solutions, Inc.
A Georgia Non-Profit Organization
Phone: 678-404-ADR1(2371)