Meet Your New Litigation Associate: Jen AI
By John Tredennick and Dr. William Webber
Watch our companion video to see GenAI in action.
Jennifer AI is a new associate starting work at your law firm. Orientation has completed and it is time for Ms. AI’s first assignment. Let’s see how she does.
Memorandum
From: David Johnson, Partner
To: Jennifer AI, Associate
Date: Tuesday, November 2, 2023 at 4:00 pm.
Regarding: Upcoming Depositions in the Bottled Water Matter
Hello Jennifer and welcome to the firm. We need your help right away.
Our client is a citizens group concerned about how Florida administrators are allowing private companies to extract water from the aquifer and sell it as bottled water. There are concerns that the companies are depleting the aquifer, causing sinkholes to swallow homes and more.
We sent out this request for production: “All documents evidencing, reflecting, or pertaining to the extraction of water in Florida for bottling by commercial enterprises.” Depositions are not yet scheduled but we need to know who to depose, from which companies and which government officials are involved in the decision making process. Ideally, we would like to know who is in whose pocket in this business.
We need your response ASAP, hopefully by the end of the week. Depositions start next Monday, November 6th.
Memorandum
From: Jennifer AI
To: David Johnson, Partner
Date: Tuesday, November 2, 2023 at 4:30 pm.
Regarding: Upcoming Depositions in the Bottled Water Matter
The issue of water extraction for bottling in Florida involves several key entities, including commercial water bottling companies, landowners, citizens groups, and government agencies.
One of the main issues is the depletion of the aquifer and the potential for this to cause sinkholes. This concern has been raised by several individuals and organizations. For example, Keith Green, a resident of Dunnellon, Florida, expressed concern that private water bottling companies like Perrier Group of America are being allowed to extract large amounts of water from Florida’s aquifer despite drought conditions (Bush1736220). Similarly, Teresa L. Weaver, a resident of Silver Springs, Florida, raised concerns about a permit granted by the St. John’s River Water Management District to withdraw up to 100,000 gallons of water per day from a site within 300 yards of Silver Springs, a famous Florida spring (Bush466670).
Another issue is the potential for commercial water extraction to disrupt longstanding public recreational uses of springs. Jon Viehe, a concerned citizen, wrote to Governor Jeb Bush about wanting to keep Florida springs open for recreational activities. He is opposed to allowing a bottling company to close Cypress Springs to the public in order to extract and sell the spring water (Bush547125).
The actions of specific bottled water companies have also been called into question. For example, Paul A. O’Byrne, MPH of Thonotosassa, Florida, sent an email to Governor Jeb Bush discussing issues with Perrier Bottled Water Co. pumping water from the Crystal Springs aquifer and the headwaters of the Hillsborough River in Zephyrhills, Florida (Bush067636). Similarly, Brad Willis, Vice President of Save Our Springs, sent an email to Mr. Boscan at the Florida Department of Environmental Protection regarding concerns about the water bottling company Perrier’s operations in Florida (Bush061164).
In summary, the main issues raised are that commercial water extraction for bottling is depleting Florida’s aquifer, potentially causing sinkholes, disrupting public recreational uses of springs, and that specific bottled water companies are not adhering to regulations and permits. These issues have been raised by a variety of individuals and organizations, including concerned citizens, residents of affected areas, and representatives of citizens groups.
Memorandum
From: David Johnson, Partner
To: Jennifer AI
Date: Tuesday, November 2, 2023 at 4:45 pm.
Regarding: Upcoming Depositions in the Bottled Water Matter
Thanks for your quick response.
I would like to know more about the possible depletion of the Florida aquifer? What are the key concerns here and who is raising them? It may be important to our case.
Thanks again for your help.
Memorandum
From: Jennifer AI
To: David Johnson, Partner
Date: Tuesday, November 2, 2023 at 5:00 pm.
Regarding: Upcoming Depositions in the Bottled Water Matter
Here are several key concerns being raised by different individuals:
Keith Green, a resident of Dunnellon, Florida (Bush1736220)
- Private water bottling companies like Perrier Group of America are extracting large amounts of water from Florida’s aquifer despite drought conditions.
- Residents are being asked to conserve water, but commercial enterprises are allowed to pump large volumes for bottling and sale.
- The water bottling operations may lower the water table and dry local wells.
- There are questions about whether the amount of water being extracted is sustainable without harming the aquifer.
Teresa L. Weaver, a resident of Silver Springs, Florida (Bush466670)
- A permit granted by the St. John’s River Water Management District allows the withdrawal of up to 100,000 gallons of water per day from a site near Silver Springs.
- The withdrawal may negatively impact Silver Springs, which has already suffered from development.
- No minimum flows and levels have been set for Silver Springs to determine how much withdrawal would be too much.
Paul A. O’Byrne, MPH of Thonotosassa, Florida (Bush067636)
- Perrier Bottled Water Co. has been pumping water from the Crystal Springs aquifer and the headwaters of the Hillsborough River.
- Despite permit denials, the company has illegally continued pumping large volumes of water, drying up the flow of the Hillsborough River, which is a source of drinking water for Tampa.
- The company did not cut back pumping during a regional drought and continued taking water to sell for profit rather than conserving the shared community resource.
Brad Willis, Vice President of Save Our Springs (Bush061164)
- Perrier and other water bottlers are damaging Florida’s springs and aquifer through over extraction.
- Perrier has faced problems wherever it operates in the US, with citizens in Wisconsin voting against allowing Perrier to operate there.
- Perrier is said to be pumping more water from Crystal Springs than allowed by the consumption permit, reducing the spring’s flow.
Memorandum
From: David Johnson, Partner
To: Jennifer AI
Date: Tuesday, November 2, 2023 at 5:15 pm.
Regarding: Upcoming Depositions in the Bottled Water Matter
Thanks again for your quick response.
It would help to have a timeline for the major events in this matter as we prepare for depositions. Could you prepare one for me when you have time.
You are doing great work here, far beyond what I would expect from a junior associate. Thank you for your efforts.
Memorandum
From: Jennifer AI
To: David Johnson, Partner
Date: Tuesday, November 2, 2023 at 5:45 pm.
Regarding: Upcoming Depositions in the Bottled Water Matter
I created this chronology covering the main events at issue here. I hope it is helpful.
Date | People Involved | Issue Description | Doc ID |
|---|---|---|---|
February 12, 2000 | Sharon Richwine, a housewife and mother of three from Woodbridge, Virginia (originally from Tampa, Florida) | Richwine writes to Governor Jeb Bush expressing concerns about bottling companies purchasing and controlling Florida’s freshwater springs without proper regulation or environmental protections. | Bush081339 |
June 16, 2000 | Brad Willis, Vice President of Save Our Springs | Willis sends an email to the Florida Department of Environmental Protection expressing concerns about Perrier and other water bottlers damaging Florida’s springs and aquifer through over extraction. | Bush061164 |
July 2, 2000 | Paul A. O’Byrne, MPH of Thonotosassa, Florida | O’Byrne sends an email to Governor Jeb Bush discussing issues with Perrier Bottled Water Co. pumping water from the Crystal Springs aquifer and the headwaters of the Hillsborough River in Zephyrhills, Florida. | Bush067636 |
January 17, 2003 | Brad Willis, Vice President of Save Our Springs, Inc. | Willis sends a letter to Governor Jeb Bush raising concerns about how the state of Florida is allowing commercial water bottling companies like Nestle Waters North America to extract large quantities of water from Florida’s springs and aquifers. | Bush000381 |
February 8, 2003 | Keith Green, a resident of Dunnellon, Florida | Green writes to Governor Jeb Bush, Senator Bob Graham, and Representative Nancy Argenziano expressing concern that private water bottling companies like Perrier Group of America are being allowed to extract large amounts of water from Florida’s aquifer despite drought conditions. | Bush1736220 |
January 22, 2005 | Teresa L. Weaver of 3781 Northeast 58th Avenue in Silver Springs, Florida | Weaver sends an email to Governor Jeb Bush expressing concern and disappointment about the planned development of the Avatar property in Silver Springs, Florida. She had been led to believe last year that the state was going to purchase the property to protect the Silver Springs area and its water recharge basin. | Bush862510 |
January 30, 2004 | Linda King (C-14RADISO@webtv.net) | King sends an email to Richard Cantrell and others at the Florida Department of Environmental Protection (DEP), South Florida Water Management District (SFWMD), and Charlotte County, Florida discussing a request by citizens in the Coral Rock Inc. vicinity for replacement drinking water under the Florida Water Quality Assurance Trust Fund (WQATF) due to contamination of private wells above EPA maximum contaminant levels for radioactive materials. | Bush841804 |
November 16, 2006 | David Struhs, Secretary of the Florida Department of Environmental Protection (DEP) | Struhs sends an email to Governor Jeb Bush summarizing issues relating to Nestle’s interest in bottling water from Madison Blue Spring in Florida. | Bush470992 |
Memorandum
From: David Johnson, Partner
To: Jennifer AI
Date: Tuesday, November 2, 2023 at 6:00 pm.
Regarding: Upcoming Depositions in the Bottled Water Matter
The timeline was really helpful. Thank you again for your help.
As a last question, who should we depose in the first round of depositions and why? What topics should we cover and what questions should I consider asking?
Memorandum
From: Jennifer AI
To: David Johnson, Partner
Date: Tuesday, November 2, 2023 at 6:30 pm.
Regarding: Upcoming Depositions in the Bottled Water Matter
In preparation for the upcoming depositions in our case concerning water extraction for bottling in Florida, I have identified several key individuals who could provide valuable insights and information. Below are the individuals, along with the reasons for their selection and potential questions to ask during the depositions.
Paul A. O’Byrne, MPH of Thonotosassa, Florida
Paul A. O’Byrne has raised concerns about Perrier Bottled Water Co. pumping water from the Crystal Springs aquifer and the headwaters of the Hillsborough River in Zephyrhills, Florida. He has direct knowledge of the company’s activities and their impacts on the local water resources.
Questions to ask:
What specific actions did Perrier Bottled Water Co. take that led to your concerns about the depletion of the Crystal Springs aquifer?
Can you provide any evidence or data to support your claims about the company’s water extraction activities?
What impacts have you observed or are aware of on the Hillsborough River and the local community due to Perrier’s water extraction?
Can you provide details about the company’s permit applications and the responses from regulatory authorities?
Brad Willis, Vice President of Save Our Springs
Brad Willis has been actively involved in raising concerns about the impacts of water bottling companies like Perrier on Florida’s springs and aquifer. His role in Save Our Springs gives him a broad perspective on the issues and potential impacts.
Questions to ask:
Can you provide details about the specific actions of Perrier and other water bottlers that you believe are damaging Florida’s springs and aquifer?
What evidence or data can you provide to support your claims about the impacts of these companies’ water extraction activities?
Can you discuss any regulatory or legal actions taken against these companies and the outcomes?
What actions do you believe need to be taken to protect Florida’s springs and aquifer from over extraction?
Keith Green, a resident of Dunnellon, Florida
Keith Green has expressed concern about private water bottling companies extracting large amounts of water from Florida’s aquifer despite drought conditions. His perspective as a local resident could provide valuable insights into the impacts of these activities on local water resources and communities.
Questions to ask:
Can you discuss your personal experiences and observations related to water extraction activities in your area?
What impacts have you noticed on local wells and the water table?
Can you provide any evidence or data to support your claims about the impacts of water extraction on local water resources?
What actions do you believe need to be taken to protect local water resources from over extraction?
Is This a Real Life Story?
It could be. You have correctly deduced that our associate Jen AI is a large language model (LLM), which many call generative AI.
Using manual techniques, this project might take several days to complete with a (really smart) human associate doing the work. At a billing rate of $800 an hour, the associate’s analysis might cost $15,000 or more.
With DiscoveryPartner—powered by Sherlock AI—these reports can be completed in minutes. Our hypothetical associate actually held off sending her responses for several minutes to give the appearance of being hard at work. The whole project cost about $1.00 in AI software costs.
Discovery platforms like DiscoveryPartner can use GenAI and machine-learning to do the following–in minutes rather than hours or days:
- Help create a search across two million emails (using our evaluation site for this exercise);
- Run the search, identifying the 100 most likely relevant documents (this is configurable);
- Use a GenAI model like Claude Instant to summarize the documents based on your topic description and interest (prompt);
- Rank the documents based on likely relevance (0 to 10);
- Sort the summaries in relevance order, top to bottom;
- Send the summaries to a GenAI model like GPT 4 to use for its analysis; and,
- Display the analysis complete with live links to the summaries and original emails.
Welcome to a new era of discovery. It’s a world where we can seamlessly transition from search hits to discovery answers, thanks to the extraordinary capabilities of machine learning and, particularly, generative AI.
By seamlessly integrating generative AI and other machine learning algorithms into a full-featured investigation and discovery platform like DiscoveryPartner, legal professionals can harness the immense capabilities of large language models like GPT and Claude to streamline discovery processes and quickly dive deeper into the key documents that are most relevant for the case.
A real life story? It is now. Reach out to us at merlin.tech to see our new generative AI discovery platform in action.
John Tredennick is the CEO and founder of Merlin Search Technologies.
JT@Merlin.Tech
Dr. William Webber is the Chief Data Scientist of Merlin Search Technologies.
Transforming Discovery with GenAI
Take a look at our research and GenAI platform integration work on our GenAI page.
Behind the Curtain
Our peerless associate, Jennifer AI, distinguished herself with those promptly-delivered memos and appears to be a shoe-in for the partner track. If you want a closer look at how she managed to create these memos and to peer behind the curtain as the Wizard of Oz might say, we offer this closer look at DiscoveryPartner and the steps Jen had to take to prepare her memos for the Bottled Water Matter.
The Initial Question
To start, we inserted the text of our document request: “Bottled Water — All documents concerning the extraction of water in Florida for bottling by commercial enterprises” into DiscoveryPartner’s (DP’s) search window.
We are using a unique, AI-powered process, which we call Freeform Search, to find highly relevant documents. It will ignore search syntax and even punctuation, instead focusing on the most important terms for its retrieval efforts.
The algorithmic search engine will retrieve the most likely relevant documents based on the entirety of your search.
Initial Results
Here are our initial results:
This is our snippet view, different from the traditional grid layout. It allows us to extract relevant information from the documents in a Google-like view to give you an idea of your search results. (1) You can scroll through the page or jump into individual documents to review.
The snippet results appear to be on topic so our next step is to copy the top 100 results into our Analyze folder so Sherlock can summarize and analyze the files to answer our questions.
Alternative Approach: Asking Sherlock to Suggest Keywords
Although we didn’t use this technique for this paper, you can also ask the GenAI algorithm to suggest keywords based upon its general knowledge and the documents it has reviewed. We did that and got these results:
“water extraction”, “Florida”, “aquifer”, “bottling”, “commercial enterprises”, “Zephyrhills Spring Water Company”, “Perrier Group of America”, “Nestle Corporation”, “water permit”, “Suwannee River Water Management District”, “Florida Department of Environmental Protection”, “Madison Blue Springs”, “water policy”, “drought”, “aquifer depletion”, “sinkholes”, “water conservation”, “water resources”, “water management”, “water bottling”, “water withdrawal”, “water use permit”, “consumptive use permit”, “water rationing”, “water shortage”, “water bottling plant”, “water bottling facility”, “groundwater extraction”, “water supply”, “water rights”, “water regulations”, “water legislation”, “water policy”, “water governance”, “water law”, “water conflict”, “water dispute”, “water controversy”, “water crisis”, “water issue”, “water problem”, “water challenge”, “water concern”, “water risk”, “water threat”, “water impact”, “water effect”, “water consequence”, “water result”, “water outcome”, “water damage”, “water harm”, “water detriment”, “water destruction”, “water devastation”, “water ruin”, “water loss”, “water depletion”, “water reduction”, “water decrease”, “water decline”, “water diminution”, “water shrinkage”, “water contraction”, “water lessening”, “water dwindling”, “water draining”, “water sapping”, “water emptying”, “water exhaustion”, “water exploitation”, “water overuse”, “water overexploitation”, “water overextraction”, “water overpumping”, “water oversiphoning”, “water overdraining”, “water overdepletion”, “water overconsumption”, “water overharvesting”, “water overwithdrawal”.
While we wouldn’t suggest using all of these terms, they provide additional keywords and keyword phrases we could enter into the search window for DiscoveryPartner to consider.
Summarizing the Documents
The next step is to submit our top documents to Sherlock for summarization and analysis. We start by describing what we are looking for to the GenAI engine. Our description is used to guide Sherlock’s summarization efforts and to provide an initial analysis of our topic question. In this case, let’s input the key paragraphs from the partner’s request memo to our GenAI engine.
In this case, we are asking Sherlock to read, analyze, and summarize 100 likely relevant documents which we found from our search (shown in the snippets page above). The chosen GenAI engine (Claude Instant or GPT 3.5) will quickly read all of the documents and present summaries for each, like this top-ranked summary below.
The summarization process for all 100 documents takes about 30 seconds in total.
Click on View Text to see a text version of the underlying document.
You can always view the text of the native file to make sure the summary is accurate.
Or click on View Document to see the underlying native file and tag it as may be appropriate.
Sherlock’s Analysis
After finding, summarizing, and ranking the top 100 documents, our GenAI engine provides its answers to your topical questions.
Depletion of Florida’s Aquifer
Our second question was a request for more detail on the original answer. Here was our query:
Provide more detail about the possible depletion of the Florida aquifer. What are the key concerns here and who is raising them? List each concern as a bold heading and tell me who raised the issue. Then summarize the points they make in a bolded list.
Here was Sherlock’s answer:
Give Me a Timeline
Our partner then asked for a timeline of major events. Here is the prompt we used to form our table.
Give me a timeline of events for the major events in this matter. For each list the date in bold in ascending order. Then describe in three lines the event and how it relates to this topic. Make sure to list the people discussing the event with their titles or positions. Provide separate lines for each event.
Give me your answer in table form. * Date * People Involved with titles or positions * Issue Description * Document references
Here was Sherlock’s answer:
Who Should I Depose?
Our last question was:
Who should I depose? Provide a bold heading for each person listing their name, title, and why they should be deposed. Then provide a numbered list for each, stating what questions should I ask and why.
Here was Sherlock’s answer:
As you can see, generative AI can be a powerful tool for helping Jenifer find and report on answers for her first litigation assignment.
How Can I See This for Myself?
If you would like to see Sherlock in action for yourself, reach out to one of us below or send an email to sherlock@merlin.tech. We would be happy to introduce you to Sherlock and let you try it out on your data as well. Or provide DiscoveryPartner for your next matter.
(1) Words like “to” and “the” are highlighted in this case because we left them in the freeform search. In practice we would remove those terms from our search.
About the Authors
John Tredennick (JT@Merlin.Tech) is the CEO and founder of Merlin Search Technologies, a cloud technology company that has developed a revolutionary new machine learning search algorithm called Sherlock® to help people find information in large document sets–without having to master keyword search.
Tredennick began his career as a trial lawyer and litigation partner at a national law firm. In 2000, he founded and served as CEO of Catalyst, an international e-discovery search technology company that was sold to a large public company in 2019. Over the past four decades he has written or edited eight books and countless articles on legal technology topics, spoken on five continents and served as Chair of the ABA’s Law Practice Management Section.
Dr. William Webber (wwebber@Merlin.Tech) is the Chief Data Scientist of Merlin Search Technologies. He completed his PhD in Measurement in Information Retrieval Evaluation at the University of Melbourne under Professors Alistair Moffat and Justin Zobel, and his post-doctoral research at the E-Discovery Lab of the University of Maryland under Professor Doug Oard.
With over 30 peer-reviewed scientific publications in the areas of information retrieval, statistical evaluation, and machine learning, he is a world expert in AI and statistical measurement for information retrieval and ediscovery. He has almost a decade of industry experience as a consulting data scientist to ediscovery software vendors, service providers, and law firms.
About Merlin Search Technologies
Merlin Search Technologies is a pioneer in AI and cloud technology, harnessing the transformative power of generative AI to reengineer search, investigations, and document review. With over twenty years of experience, our team has built and hosted discovery platforms for many of the largest corporations and law firms in the world.
We deliver our software securely via the cloud, using a unique single-tenant architecture for unparalleled security and flexibility. As industry trailblazers, we’re proud to offer the first-ever On/Off Cloud Utility Pricing, allowing you to reduce hosting costs and support green computing.
Our mission is to use AI and cloud technologies to make search, investigations and discovery efficient and cost effective.
If you want to learn more about Merlin or DiscoveryPartner, our GenAI-integrated discovery and investigations platform, please reach out!
