Melissa Dalziel

• Coordinated the efforts for a client and external vendor to collect 8,400 data sets; crafted and negotiated search terms and custodian selection; and managed ECA, filtering, review, and production processes of 10+ million documents in copyright infringement action that sought over $1.2 billion in damages.
• Managed the scheduling and preparation for 330 depositions of 90 defendants and third parties, training and managing the work of attorneys creating witness kits and deposition outlines in action against correspondent lenders relating to the origination and sale of defective residential mortgage loans.
• Supervised the coding of at least 40 million pages of documents, in more than 12 languages, by 300+ contract attorneys; hired, trained, and managed the contract attorney team.
• Prepared 30(b)(6) witnesses relating to document retention and collection for deposition and defended their depositions in lawsuits filed by reorganized bankrupt entity’s trust against D&O’s and auditors for breach of fiduciary duty and professional malpractice.
• Worked with ESI Laboratory, LLC to create tool to quickly eliminate false hits and identify true PII to redact in 800,000 documents in action filed by European asset managers, pension funds, and central banks against major banks for foreign currency market manipulation.

Melissa Dalziel is a member of Alston Discovery, the firm’s e-discovery team, and manages large teams during all stages of discovery and trial preparation. Melissa has overseen discovery in a wide range of intellectual property and commercial disputes, including patent, trademark, and copyright; unfair competition, fraud, and breach of contract; and RMBS, securities, and financial services.

Melissa prepares discovery budgets and develops procedures and protocols for the collection and review of massive quantities of documents. Her work includes negotiating search terms, TAR protocols, and ESI protocols, hiring, training, and managing review teams, and implementing quality controls. She uses, and trains teams regarding the use of, analytic applications such as concept clustering and technology assisted review to reduce costs and identify key documents. Melissa has conducted PII/GDPR reviews on behalf of European clients suing in U.S. courts and clients that have experienced data breaches. She advises clients and attorneys on legal developments and best practices in document preservation, collection, searching, filtering, and data privacy.

In a former role, Melissa assisted in the review and assessment of more than 20 generative AI legal tools being considered for the firm’s use. She has conducted extensive trials of four tools, using them on live cases, and is working with three providers to assist in developing their tools. She advises clients regarding the development of AI use policies.

Languages

• Spanish

Bar Admissions

• California
• Georgia (Not Admitted)

Education

• Brigham Young University (J.D., 2000)
• University of Toronto (B.A., 1997)

Memberships