Three Key Tips to Keep in Mind When Leveraging Corporate G Suite for eDiscovery

July 22, 2020



Alison Shier
Alison Shier

In the eDiscovery space, we are always spotting new trends. Our industry has seen text messages, chat message platforms, websites, and various unstructured data sources become increasingly relevant during discovery. Over the past several years, we have started to see another new trend emerge - many of our clients are using Corporate G Suite rather than Office 365.

The use of emerging technologies is part of everyday life for many companies in the space. However, we are beginning to see established biotech, healthcare, manufacturing, and retailers shift to G Suite, an area that was once almost exclusively dominated by on-prem Microsoft products. This transition introduces some new considerations around managing discovery. In this post, we talk about three impacts that G Suite data has on downstream eDiscovery workflows, and the need to factor these items into your discovery plan.

  • Recipient Metadata: Gmail renders email header information in a unique format. While the last-in-time email in a given string will have all expected sender and recipient information (From, To, CC, BCC), all other previous messages exchanged in the email string will display only the sender information and will not display the recipient information. This is not a collection, processing, metadata, or threading issue. Rather, this relates to how Gmail stores and exports recipient information. This presents some unique document review challenges, as previous parts of the thread could include recipients that are not visible to the reviewer, and may include attorneys who have sent privileged communications. As a result, it is important to work closely with your project management team to create workflows related to Gmail.
  • Links: Historically, we have all attached copies of documents (e.g. Word, Excel, and PowerPoint files) to an email during the normal course of business. Due to the emergence of technologies such as SharePoint and Google Drive, we now have the ability to send emails with embedded links that reference documents rather than attaching the document itself. When Gmail is exported from Google Vault, the documents referenced in links embedded throughout email exchanges are not exported. As a result, reviewers will encounter these links, but will be unable to readily view the corresponding document referenced in said link. At present, Google Vault does not allow for the mass search and export of these links. However, you do have the ability to manually pull documents referenced in these links. You should be mindful of this issue when drafting your ESI protocol, as opposing parties and regulators may request that your company retrieve these documents.
  • Exported Load File: Unlike a standard PST export, when you export a mailbox or set of documents from Google Vault, you have the ability to retrieve a corresponding load file that contains metadata captured in G Suite. Sometimes, the date-related metadata extracted during processing, will not align with dates exported from G Suite. There are a variety of legitimate reasons for this. You will need to determine if you want to produce the date metadata extracted from the processing platform, date values exported from Vault, or both.

All of the above items are manageable when in-house legal teams, outside counsel, and eDiscovery vendors work together to proactively implement appropriate downstream eDiscovery workflows.  If you have experience with G Suite data or thoughts on managing the discovery of G Suite data, please reach out to me at

About the Author

Alison Shier

Alison is a seasoned eDiscovery professional with a career spanning almost 15 years. Alison began in Arnold & Porter’s antitrust group where she managed day-to-day eDiscovery for complex DOJ and FTC second requests and antitrust litigation. After leaving the firm, she went on to work for a global eDiscovery provider. Within 2 years, she became one of ten National Account Directors. In this capacity, Alison was responsible for overseeing delivery for one of the largest global financial institutions and was charged with building and refining their eDiscovery program and playbook.

Alison has spent the last 8 years at Lighthouse, where she serves as Senior Director of Client Solutions and Success. Her collaborative approach and dedication are evident in her longstanding client partnerships. Her core clients include more than a dozen Fortune 500 multinational corporations that span the telecommunications, retail, technology, pharmaceutical, and energy industries, as well as ten of the top AMLaw 200 law firms.

Alison’s chief role is to guide corporations and law firms through the evolution of their eDiscovery programs. Alison advises on a wide array of topics ranging from Information Governance to the implementation of insourced technology, to the application of Review Intelligence.

Over the years, Alison has earned a reputation for architecting innovative solutions from the deployment of novel M356 modern attachment workflows to her role in helping clients adopt predictive and generative AI-based solutions.

Alison is not just a practitioner but also an industry thought leader and community member. She regularly serves as an expert speaker on industry panels; including most recently EDI’s 2023 conference where she led a discussion around agile review workflows that integrate Large Language Models. She has also been featured on the podcast Law & Candor where she described the nuances of managing complex data sources exported from Google Vault.

She is a member of Lighthouse’s WLEAD Employee Resource Group which supports the growth, advancement, and inclusion of women. She has served as a mentor in the WLEAD Mentorship program, assisting others at Lighthouse in achieving their career goals. She is a member of the New York City chapter of Women in eDiscovery (WiE).

Alison graduated Phi Beta Kappa from the University of Michigan with a degree in organizational management and consulting. She also served as a Research Assistant to Professor Daniel Katz at the Centre for the Study of Complex Systems at the University of Michigan Law School. She later served as a Research Fellow to Professor Jane Dutton at the Ross School of Business.