First off, the answer to the question in the title is, yes, of course. But, this is one point that really stuck with me, because over the years as a trainer, and working in law firms, I’m always left a little stunned by lawyers who talk about not knowing what the search for until they start reviewing.
“In many jurisdictions, there is a whole generation of young lawyers who have not been trained to effectively interview witnesses and who turn instead to mechanically review the documents at the beginning of a case in search of insight into the facts and issues.”
If you want to know what search terms, date ranges, custodians, etc. to use, talk to people. Otherwise you’re just reading documents, a lot!