Expedited Discovery

Responsive | Accurate | Immediate

Collect, Review, and Produce when you only have days.

Delaware’s Court of Chancery has broad power to expedite discovery for cases involving preliminary injunctions. The scope and timing of discovery in these high stakes commercial and corporate litigations are greatly compressed and can impose considerable burden on the parties. With expedited discovery, the Court encourages the prompt collection of “core documents” from “key custodians”. These key custodians may be board of directors members, corporate executives or their investment advisors. Their documents may be stored in a number of locations including on networks (email servers, SharePoint, network shares), personal devices (laptops, tablets, iPhone) or cloud-based mail (Yahoo, Gmail, Microsoft 365).

Parcels works with counsel to quickly identify, collect, process and review documents using search terms, date restrictions and advanced computer analytics. At the direction of counsel, we will prioritize the production of “core” and “significant” documents on a “rolling basis”. If the parties agree to a “quick peek” review, Parcels can provide productions in native, TIFF, or PDF format.  We’ll coordinate with review teams and implement efficient workflows to meet the most demanding deadlines.

Our team has decades of experience handling expedited discovery cases and will help you address issues related to:

  • Alleviating burden to the parties
  • Scope and timing of expedited discovery
  • High stakes commercial and corporate litigation discovery challenges
  • Working with a court appointed discovery master
  • Collection of “Core Documents” which typically include:
    • Minutes of the relevant meetings of the board of directors and any board committees
    • Materials provided to the directors related to the transaction
    • Working group lists associated with the transaction
    • Engagement agreements and fee arrangements with investment advisors
  • Preparing for Section 220 “Stockholder Inspection Rights” or “Books and Records” matters
  • Discovery issues related to stock appraisal matters
  • Coordination with key custodians to collect data from parties with little or no technical know-how.
  • Assisting counsel with interviews of custodians from whom they have collected to understand, among other things, any potential sources of relevant documents
    • centralized document repositories or systems, cloud based storage
    • PDAs, mobile phones, tablets
    • work and home computers and external flash/thumb/jump drives
  • Production of significant documents as soon as possible, and all other documents on a rolling basis as encouraged by the Court
  • “Quick peek” agreements whereby the party seeking discovery is permitted to review responsive documents without effectuating a waiver of privilege by the producing party
  • Handling discovery of third parties, such as investment advisors and others with fiduciary responsibilities

Expedited Discovery

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FAQs

How is Expedited Discovery different from Standard Discovery?

Standard discovery typically unfolds over months, allowing time to negotiate scope, identify custodians, and process large data sets. Expedited discovery condenses all of this into days. The focus shifts from comprehensive collection to identifying and producing “core documents” from key players—such as board members, executives, or advisors. Instead of broad requests, the goal is targeted, strategic production that satisfies the Court’s immediate information needs.

Why Does Expedited Discovery Matter in Delaware’s Court of Chancery?

Delaware’s Court of Chancery handles complex corporate litigation that often influences national business law. Because time-sensitive decisions can impact shareholder rights or merger outcomes, the Court routinely grants motions to expedite. Parties must produce targeted discovery, fast. Parcels’ team has decades of experience navigating this unique environment, ensuring compliance with the Court’s expectations and with the technical realities of tight turnaround document collection.

What Types of Documents are Typically Collected?

Under expedited discovery, focus centers on “core” materials from “key custodians.” These may include:

- Board and committee meeting minutes
- Transaction-related presentations or working group lists
- Engagement letters and fee arrangements with advisors
- Emails and files stored across servers, cloud systems, and personal devices

Parcels locates and collects this information from networks (such as SharePoint or Microsoft 365), laptops, and mobile devices wherever evidence resides. Even non-technical custodians can rely on Parcels to facilitate seamless data transfers and maintain the chain of custody.

How Does Parcels Manage Time-Sensitive Collections and Reviews?

Speed and precision define Parcels’ process. Working at counsel’s direction, Parcels uses advanced search terms, date filters, and analytics to quickly isolate responsive documents. Productions are delivered on a rolling basis, prioritizing “significant” materials first. When parties agree to a “quick peek” review, Parcels provides files in native, TIFF, or PDF format so counsel can evaluate them immediately. Coordination with legal review teams ensures that every document meets evidentiary and privilege standards despite the compressed timeframe.

What are Common Challenges in Expedited Discovery, and How Does Parcels Solve Them?

- Burden Reduction: Parcels minimizes disruption to corporate teams by centralizing collection.
- Data Diversity: From mobile devices to cloud repositories, Parcels ensures nothing slips through the cracks.
- Privilege Control: “Quick peek” arrangements are handled carefully to avoid inadvertent waiver.
- Third-Party Involvement: When investment advisors or consultants hold relevant data, Parcels facilitates lawful, efficient collection. The result is a defensible, court-ready discovery process that meets the Court’s speed and accuracy expectations.

When Should a Legal Team Bring Parcels into an Expedited Case?

As soon as a motion to expedite is filed or anticipated. Early involvement allows Parcels to establish preservation protocols, identify core data sources, and align with counsel before the Court imposes discovery deadlines. Our team can mobilize immediately and scale resources to meet any demand.

Ready to Take Control of Expedited Discovery?

When discovery deadlines shrink, preparation and precision make all the difference. Parcels combines decades of Chancery experience with advanced technology to help legal teams collect, review, and produce defensibly, no matter how short the clock. 

Need immediate assistance with an expedited discovery matter? Contact us today! Our experts are ready to help you collect, review, and produce with speed, accuracy, and confidence.