In this addition of our ongoing series on e-discovery issues and best practices we will explore the discovery landscape for complex litigations that often have parallel matters in either state court or federal court. We will define strategic objectives and best practices for managing discovery in mass tort actions, such as multidistrict litigations (MDLs), and similar large litigations.

At its core, discovery in MDLs is no different than that of an average litigation. The fundamental concepts, processes and practices are the same. However, the success of managing large complex matters will fall squarely on the e-data attorney's ability to plan strategically and communicate effectively with co-counsel and various opposing counsel law firms especially when there are parallel matters at play.