Complex litigation frequently stalls over contentious discovery disputes, massive E-discovery requests, and complex privilege logs. Judges, burdened with overwhelming dockets, often lack the time to parse through thousands of contested documents.

Alvarez Dispute Resolution offers Special Master and Discovery Referee services to unblock these bottlenecks.

Scope of Special Master Services

Operating either by court appointment or mutual agreement of the parties, our neutrals provide detailed, hands-on oversight for complex pre-trial matters. We issue swift, well-reasoned Reports and Recommendations (R&Rs) to the presiding judge.

We Commonly Assist With

  • E-Discovery Protocols. Managing the scope, search terms, and production parameters of electronically stored information (ESI).
  • In Camera Reviews. Conducting meticulous reviews of contested documents, privilege logs, and trade secret redactions.
  • Pre-Trial Motions. Resolving motions to compel, motions for protective orders, and spoliation claims efficiently.
  • Accounting & Valuation. Overseeing complex financial accounting and equitable distribution phases.

Why Appoint a Discovery Referee?

Appointing a Special Master ensures that discovery disputes are handled within days, rather than waiting months for a hearing on a judge’s motion calendar. It keeps the litigation timeline intact, reduces overall client costs, and allows trial counsel to focus on case strategy rather than discovery warfare.

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