Way back in December 2003 I posted about the Seventh Circle of Document Review Hell in the context of a nasty discovery dispute in the Kerkorian-DaimlerChrysler trial:

Can it get much worse for the poor souls who were forced to testify about the failure to produce these documents? Is this not the Seventh Circle of Document Review Hell? I suggest the Circles run something like this:

Circle 1. Reviewing corporate M&A documents for litigation. Period.
Circle 2. Reviewing millions of corporate M&A documents for litigation, over a long period of time.
Circle 3. Reviewing millions of corporate M&A documents for litigation, over a long period of time, for a multi-billion dollar case where a momentary lapse in concentration or judgment can have high dollar repercussions and be highly "career limiting."
Circle 4. Same as Circle 3, but also, against staggering odds, the multi-billion dollar case goes to trial and receives international attention.
Circle 5. Same as Circle 4, but also learning in the middle of trial that 60+ pages of "explosive" documents were not produced by your side.
Circle 6. Same as Circle 5, but also learning that the Court has actually suspended the multi-billion dollar trial to hold a special adversarial hearing to determine exactly why the documents were not produced.

and finally...

Circle 7. Same as Circle 6, but also learning that you must take the stand to explain, and be aggressively cross-examined on, why the documents were not produced.

Well, if it isn't in the Seventh Circle it's darn close when, as reported earlier today, you are an associate in a big law firm and after working on an acquisition and discussing it in confidence with your live-in boyfriend, you see your boyfriend's name "on a list of individuals who had traded in the stock which had been sent from the NASD as part of its routine market surveillance operations."