Management Representative

Diane E. Barry, Esq.

***** ********** ******, #***, ********** Beach, CA 92646 415-***-****

( *****.*****@*****.***

Publications

Matthew Bender/LexisNexis practice guide "California E-Discovery &

Evidence". Sole Author of 5 Chapters: (1) Ethical Issues for Attorneys in

E-Discovery; (2) Discovery of ESI Residing in Foreign Jurisdictions; (3)

Establishing Best Practices Regarding Electronically Stored Information

(4) E-Discovery Deposition Practice; (5) Admissibility of Electronic

Evidence at Trial. Co-Author of Chapter "Understanding Electronic

Evidence."

Professional Experience

International Litigation Services. Los Angeles, CA - Director, Discovery

Strategy & Management - February 2009 - Present

. Responsible for creation of new line of business in ESI discovery

consulting. Working closely with Marketing/Sales to create product

lines and descriptions as well as cross marketing opportunities with

existing service lines.

. Responsible for providing cutting edge discovery and ediscovery advice

to litigation and investigation target clients, in civil, criminal,

state and federal court settings. Engagements include work as

technical advisor to federal court special master for ediscovery

(Mattel v. MGA, Central District of California); planning and

supervision of ESI collections in the EU (Terra Firma Capital Partners

v. Citibank, Southern District of New York); Ediscovery Expert Advisor

to Plaintiff's Committee - Toyota Class Actions (Central District of

California). Work with clients includes: Legal discovery strategy and

planning (offensive and defensive); planning and management of ESI

collections; support for law and motion practice (drafting and

research), orders and stipulations; attend and assist with discovery

conferences and other hearings, 30(b)(6) / PMK deposition preparation.

Client base includes neutrals, outside counsel firms and in-house

counsel departments. Current matters include Intellectual Property,

Products Liability, Criminal Defense, Complex Financial Transactions;

Construction.

. Responsible for creation of new line of business in large scale

document review consulting and services. Privilege review,

responsiveness review; issue research. Service offerings include

consulting to increase efficiency and quality of existing review

processes, through full provision of review facilities, staff and

management. Onshore and offshore options available.

. Responsible for increasing firm and consulting division visibility and

credibility through publishing, and public speaking opportunities.

Typical speaking engagements: American Bar Association 4th Annual

EDiscovery Institute, Panelist Admissibility of ESI - May 27, 2010;

Alameda County Bar Association, Ethical & Professional Obligations in

eDiscovery - August 18, 2010; LexisNexis / Matthew Bender Ediscovery

Experts Panel on AB05 - December 9, 2010; Women in EDiscovery (San

Diego &San Francisco Chapters) Expert Panels on AB05 - September 2009;

Instructor at Guidance Software Computer Enterprise Investigator's

Conference, Taking and Defending 30(b)(6) Depositions May 2009; IQPC

eDiscovery Conference, San Francisco, Taking and Defending 30(b)(6)

Depositions - April 2009.

iQwest IT, Inc. - eCouncil Division, Tustin, CA - Director, Discovery

Strategy & Management

March 2008 - February 2009

. Responsible for creation of new line of business in ESI discovery

consulting. Worked closely with Marketing/Sales to identify target

market, product line and product descriptions, as well as cross

marketing opportunities with existing service lines. Brought in new

clients who would not formerly have been interested in the services of

iQwest IT. Representative new client engagements included large scale

IP patent prosecution which included consulting regarding foreign

language review strategies and cross-lingual tools; Several small law

firms (5 to 80 attorneys - ESI discovery planning and strategy); The

Office of the City Attorney for the City of Los Angeles (Discovery

consulting for police action against health insurance carriers);

Shernoff Bidart Darras & Echeverria (Discovery consulting - plaintiff

firm specializing in bad faith insurance matters);

. Responsible for representing consulting division in joint marketing and

joint opportunity bidding with iQwest partners. Established good

working relationships with partner contacts in areas of on and offshore

document review teams; ESI collection; forensic examination.

. Responsible for increasing firm and consulting division visibility

through CLE and panel speaker opportunities. Representative speaking

engagements: ESI Discovery section of Annual Rutter/Group/Shernoff Bad

Faith Insurance CLE day - December 2008 ("Exposing Your Opponent's

Secrets Through eDiscovery"); Criminal CLEs at Offices of Federal

Public Defenders (Las Vegas, Denver); eDiscovery under the New CCP

Provisions (full day CLE for National Business Institute, December

2008).

LECG LLC - e-Discovery Practice Group, San Francisco -Senior Managing

Consultant

January 2007 - March 2008

. Responsible for increasing San Francisco office participation in

national litigation preparedness practice and ESI discovery consulting

engagements. Representative engagements included both pre-litigation

and litigation matters, internal as well as and government

investigations. Representative projects included drafting e-discovery

policies and procedures, discovery planning, support to forensic

accounting investigations, project management and coordination of

multidisciplinary teams.

. Responsible for drafting and presenting CLE and other training modules

on topics such as computer forensics, preparation of collection plans,

preparation for FRCP 26(f) conferences, e-discovery and malpractice

issues, discovery of databases. Representative speaking opportunities

included: ESI Discovery in Nevada (Institute for Paralegal Education -

Las Vegas, NV August 22, 2007) and eDiscovery Strategies and Best

Practices (National Business Institute San Francisco/Oakland/ Fresno,

August 28 - 30, 2007)

Deets Consulting Group, San Francisco / Las Vegas - Attorney & Sr.

Consultant - August 2001- December 2006 Complex Litigation Consulting

Securities / Antitrust / Business Torts / Fraud / Construction

. Attorney Responsibilities: Direct assignment as member of law firm

litigation teams, functioning as associate in charge of discovery.

Direct contact with both partners and clients. Responsible for

planning and conducting complex discovery (electronic and paper

evidence), both offensive and defensive, from identification of

evidence through collection and production; drafting and arguing

associated law and motion. Designed and supervised massive privilege

and relevance review projects. Court and arbitration hearings;

dispositive motions; depositions (Custodian/PMK/witness); mediation and

settlement presentations.

. Consulting / Project Management: Responsible for "ghost writing' and

ESI discovery coaching to attorneys at law firm clients, as well as

electronic discovery planning and management services. Representative

work projects included discovery issue research writing and advice,

planning and implementation of ESI discovery/complex discovery plans,

including vendor selection; computer tool selection collection process

design; database design, drafting RFPs, work process documents and

vendor contracts.

Gordon & Rees, San Francisco, CA - San Francisco, CA - Special Projects

Attorney

September 1999- August 2001

. Functioned as associate in charge of discovery in Business Practices

Group. Patent/trademark disputes, federal securities fraud; contract

disputes Responsible for general case management. Conducted discovery of

both paper and electronic evidence sources. Drafted and argued discovery

motions, dispositive motions; motions in limine, general legal research

and writing. Direct contact with partners, clients, opposing counsel.

. Member of Labor & Employment trial preparation team defending government

client in A.D.A. Title II suit for denial of physical access. Responsible

for research and drafting of motions in limine.

Heller Ehrman White & McAuliffe, San Francisco, CA - Special Projects

Attorney

May 1998- September 1999

. Stull v. Bank of America: Project lead for Intervenor Field team.

Responsible for paper and data discovery of over 400

intervenors/plaintiffs. Planned and conducted same; trained and managed

up to 3 field teams working multiple sites across California. Designed

collection strategies and process, training and quality control process

and materials. Designed complex litigation support database. Dealt

directly with opposing counsel; appeared before discovery referee; wrote

and argued law and motion. Took PMK and custodian depositions.

Participated in trial preparation, including drafting of trial exhibits.

Also assigned to team responsible for oversight of imaging and database

coding vendors. Responsibilities included data validation projects and

training of off site coding staff, participation in data scrub projects.

. Developed in-house seminar series on discovery of electronic data sources

and electronic data retention policies. (First ever for firm, nationwide)

Drafted internal ediscovery practice guide.

Richard J. Mathias & Associates, Los Angeles, CA - Litigation Associate -

Labor & Employment/Unfair Business Practices - April 1996-March 1997

. Responsible for all aspects of case prosecution and management. Planned

and implemented litigation strategy from inception through disposition.

Complaints, answers, interrogatories, depositions including ESI discovery.

Drafted and argued law and motion; dispositive motions. Internal

investigations. Client counseling. Representative matters included

intellectual property and trade secrets; union/labor organization internal

governance dispute; employment defense.

Sonnenschein, Nath & Rosenthal, Los Angeles, CA - Special Projects Attorney

- Labor & Employment/Unfair Business Practices - June 1994-April 1996

. Labor & Employment law / protection of trade secrets / trademark & trade

dress / copyright. Responsible for state and federal court matters:

conducted discovery, including ESI discovery, attended court hearing and

depositions. Researched, wrote and argued discovery motions, motion to

dismiss, for judgment on the pleadings and for summary judgment.

Solo Practitioner, Los Angeles, CA - February 1992-May 1994

. Responsible for creating and maintaining a solo litigation practice.

Practice focus: civil litigation for individual and small corporate

clients (25 or fewer employees).

. Responsible clients in all aspects of litigation: complaints,

investigation,discovery, depositions, motions, ex parte matters,

restraining orders, arbitrations. Appeared in state and federal courts

throughout the Los Angeles County area. Particular concentration in areas

of labor/employment law and government contracts, both pre-litigation

counseling as well as litigation of claims, and business torts.

. Also participated in client internal investigation matters as requested.

Kirkland & Ellis, Los Angeles, CA - Litigation Associate - Civil Litigation

& Government -Contracts Areas - October 1990-February 1992

. Responsibilities included general discovery, drafting motions, taking

depositions, negotiations with opposing counsel. Solely responsible for

matters involving unfair business practices, forum selection, business

tort and fraud allegations.

. Team member regarding government contractor internal investigations and

Qui Tam suit litigation. Assisted in preparation of a voluntary

disclosure report and responses to civil investigative demands.

Poindexter & Doutr , Los Angeles, CA - Associate - September 1989-October

1990

. Responsibilities included drafting complaints, conducting discovery,

preparation and defense of discovery motions, taking depositions,

settlement negotiations. Appeared in court for Law and Motion calendar

and conferences. Responsible for all aspects of litigation cases

assigned.

Education

Boston University School of Law - J.D. cum laude, 1989

Tauro Scholar (top 25% of 1st year class); Liacos Scholar (top 25% of 2nd

year class);

Hennessey Scholar (top 25% of 3rd year class); Director Stone Moot Court

Program; ATLA Trial Team (Regional Semi-Finalist); Clinical Prosecutors

Program; American Jurisprudence Award for Civil Procedure; Judge/Advisor

First Year Moot Court Program

Vassar College, A.B. Political Science, 1983

Strong House Treasurer & Board of Elections, Choir Officer

University of California at Berkeley, Data Warehousing Certification 1999

Professional/Technical Certification - certifies completion of 5 courses

in area of study, with B+ average

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