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The Litigation Section of the State Bar of Texas recently published an article in The Advocate authored by Gunster Shareholders Christine Payne and Adam Nodzenski. The article, entitled “Simple Ways to Make Search-Term Negotiation More Bearable,” provides practical advice on navigating search terms as part of the discovery process.

In the article, Payne and Nodzenski comment on utilizing effective search terms, breaking down long strings, and use of the “hits” and the “lockbox method.” “While negotiating parties may consider many different search terms, some are more likely to be used than others … What is likely to happen is that one side will propose a list of search terms to the other,” they go on to explain.


Gunster attorney Christine Payne

Christine Payne is a nationally recognized litigator focused on e-discovery and overarching litigation strategy. She brings practical skill to high-dollar, bet-the-company cases, handling all aspects of discovery for complex commercial litigation, restructuring-related litigation, product liability litigation, antitrust matters, Section 220 requests and ongoing or anticipated investigations.


Gunster attorney Adam Nodzenski

Adam Nodzenski is a leader within Gunster’s eDiscovery group who focuses on practical solutions for clients involved in the biggest of cases—multi-plaintiff, multi-jurisdictional, and/or multi-claim litigation—which are often protracted and involve multiple law firms. Adam provides advice regarding data identification, preservation, collection, review and production, and assists companies recovering from data loss or those defending against spoliation allegations. 

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