Giyoung Song represents financial institutions, corporations and individuals in complex litigation involving corporate, commercial and securities-related matters in federal and state courts.


Ms. Song’s practice is dedicated primarily to discovery-focused litigation, advice and counsel in federal and state court-based class actions, multidistrict litigation and other disputes.

She has extensive experience litigating and managing complex and sophisticated discovery issues, and regularly advises clients regarding discovery law, best practices and practical solutions. She also acts as discovery and coordinating counsel for financial institutions, and advises in-house counsel and outside counsel firms on a broad range of subject matters relating to the clients’ discovery practices and procedures, and litigation strategy.

Ms. Song’s experience includes:

  • Early case assessment and early data assessment – developing litigation strategy, formulating budgets, preparing case management plans, and identifying key documents and important witnesses to assess the determinative facts of the case.
  • Identification – implementing and advising on a cost-efficient and defensible process for identifying relevant documents, witnesses and other sources of information.
  • Preservation – advising clients regarding implementation and monitoring of preservation plans.
  • Discovery negotiations – conducting meet and confers regarding discovery issues, formulating strategies to manage the scope of discovery, and negotiating reasonable and proportional discovery protocols.
  • Document collection, processing, review and production – advising clients and firm lawyers on best practices, and developing and implementing defensible, cost-effective protocols and guidelines for collection, processing, review and production of relevant information.
  • Privilege review and privilege logs – consulting on privilege and privacy law issues, and planning and managing large-scale privilege review projects and preparation of defensible and efficient privilege logs.
  • Witness interviews and depositions – conducting fact investigations and witness interviews, and formulating, implementing and advising on strategies for reviewing and identifying documents for offensive and defensive depositions, summary judgment and trial.
  • Discovery vendor and cost management – managing clients’ and firm’s discovery vendors; training and supervising contract attorneys for document review projects; and preparing discovery budgets and controlling discovery costs.
  • Cross-case coordination – assisting clients in enhancing consistency and efficiency, and create synergy through cross-case coordination strategy and leveraging, and knowledge sharing.



  • J.D., Benjamin N. Cardozo School of Law, 2002
  • B.S., Syracuse University, 1994


  • New York

Giyoung Song

Discovery Counsel, Complex Litigation and Trials