https://tailoredmediation.com/insights Writing on technically complex dispute resolution — AI, digital forensics, cyber insurance coverage, eDiscovery — by Daniel B. Garrie, Esq. en-us © 2026 Daniel B. Garrie, Esq. info@tailoredmediation.com (Daniel B. Garrie, Esq.) Mon, 31 Aug 2026 12:00:00 GMT https://tailoredmediation.com/insights/special-master-appointment-order https://tailoredmediation.com/insights/special-master-appointment-order Mon, 31 Aug 2026 12:00:00 GMT Rule 53(b)(2) forces four decisions into every appointment order. Left undrafted, a court fills them in — rarely the way a technical dispute needs. Daniel B. Garrie, Esq. https://tailoredmediation.com/insights/cyber-bi-quantum https://tailoredmediation.com/insights/cyber-bi-quantum Tue, 25 Aug 2026 12:00:00 GMT Coverage arguments get the attention. The number gets the money — and it is assembled, or lost, by people restoring systems who are not thinking about a proof of loss. Daniel B. Garrie, Esq. https://tailoredmediation.com/insights/cyber-coverage-record https://tailoredmediation.com/insights/cyber-coverage-record Tue, 25 Aug 2026 12:00:00 GMT A coverage dispute is decided in the first hours after a breach, by people not thinking about coverage. How to build that record — and how a neutral uses it. Daniel B. Garrie, Esq. https://tailoredmediation.com/insights/technical-mediation-stipulations https://tailoredmediation.com/insights/technical-mediation-stipulations Tue, 18 Aug 2026 12:00:00 GMT In a dispute that turns on technology, the first hours of a mediation are usually spent establishing what the system did — not negotiating. Most of that work can be finished before anyone sits down. Daniel B. Garrie, Esq. https://tailoredmediation.com/insights/agentic-ai-liability https://tailoredmediation.com/insights/agentic-ai-liability Sat, 01 Aug 2026 12:00:00 GMT When an autonomous system takes the action in dispute, the evidence explaining it sits in four record types on short retention clocks. The technique is knowing what to freeze, and in what order. Daniel B. Garrie, Esq. https://tailoredmediation.com/insights/deepfakes https://tailoredmediation.com/insights/deepfakes Tue, 09 Jun 2026 12:00:00 GMT How generative AI defeats casual inspection of audio-visual evidence, what FRE 901 actually requires, and a practical protocol for authenticating suspect media. Daniel B. Garrie, Esq. https://tailoredmediation.com/insights/forensic-selection https://tailoredmediation.com/insights/forensic-selection Thu, 04 Jun 2026 12:00:00 GMT Six questions that vet a forensic neutral the way a court vets a forensic report — qualifications, acquisition, tools, and whether findings can be reproduced. Daniel B. Garrie, Esq. https://tailoredmediation.com/insights/smart-contracts https://tailoredmediation.com/insights/smart-contracts Thu, 28 May 2026 12:00:00 GMT A smart contract executes exactly as written, right or wrong. Resolving what happens next takes arbitration rules built for code and a neutral who can read it. Daniel B. Garrie, Esq. https://tailoredmediation.com/insights/jams-ai-rules https://tailoredmediation.com/insights/jams-ai-rules Sun, 17 May 2026 12:00:00 GMT Why conventional e-discovery breaks down when the evidence is an evolving AI system, and how the JAMS AI Rules restore proportionality and technical competence. Daniel B. Garrie, Esq. https://tailoredmediation.com/insights/cyber-insurance https://tailoredmediation.com/insights/cyber-insurance Wed, 06 May 2026 12:00:00 GMT Cyber policy forms change faster than precedent can settle them. Why coverage disputes resolve better in mediation and arbitration, and how to draft the clause. Daniel B. Garrie, Esq. https://tailoredmediation.com/insights/protective-order https://tailoredmediation.com/insights/protective-order Fri, 24 Apr 2026 12:00:00 GMT Model weights, training data, prompts and outputs are not the same kind of secret. How the JAMS AI Rules support graduated, artifact-by-artifact access. Daniel B. Garrie, Esq. https://tailoredmediation.com/insights/special-master-tar https://tailoredmediation.com/insights/special-master-tar Thu, 09 Apr 2026 12:00:00 GMT Courts settled whether parties may use TAR years ago. The disputes now are over protocols and validation — and early special-master appointment avoids them. Daniel B. Garrie, Esq. https://tailoredmediation.com/insights/hallucinations https://tailoredmediation.com/insights/hallucinations Sat, 14 Mar 2026 12:00:00 GMT Hallucinated authority is not a software glitch. It is a breach of the duty of competence that taxes every party in the room and endangers the award itself. Daniel B. Garrie, Esq. https://tailoredmediation.com/insights/cross-border https://tailoredmediation.com/insights/cross-border Wed, 11 Mar 2026 12:00:00 GMT GDPR, Schrems II, and divergent disclosure regimes have turned cross-border forensic collection from a logistics exercise into a conflict-of-laws problem. Daniel B. Garrie, Esq. https://tailoredmediation.com/insights/forensic-data https://tailoredmediation.com/insights/forensic-data Sun, 22 Feb 2026 12:00:00 GMT The forensic record is treated as trial ammunition. Produced by a neutral under an agreed protocol, it is also a settlement instrument that narrows the fight. Daniel B. Garrie, Esq. https://tailoredmediation.com/insights/special-master-economy https://tailoredmediation.com/insights/special-master-economy Sat, 14 Feb 2026 12:00:00 GMT Special masters cost money. The disputes they absorb — protocol fights, compliance, fee allocation — routinely cost more. Where the appointment pays for itself. Daniel B. Garrie, Esq. https://tailoredmediation.com/insights/evolution https://tailoredmediation.com/insights/evolution Fri, 09 Jan 2026 12:00:00 GMT How the technical neutral became a distinct role — from the 2006 e-discovery amendments and special masters to forensic appointments and the JAMS AI rules. Daniel B. Garrie, Esq. https://tailoredmediation.com/insights/ediscovery-ai-adr https://tailoredmediation.com/insights/ediscovery-ai-adr Mon, 17 Feb 2025 12:00:00 GMT How eDiscovery and AI reshape arbitration and mediation: TAR, predictive coding, data-privacy duties, and the ethics of disclosing AI use to a tribunal. Daniel B. Garrie, Esq. https://tailoredmediation.com/insights/forensic-neutrals-litigation https://tailoredmediation.com/insights/forensic-neutrals-litigation Tue, 28 Jan 2025 12:00:00 GMT How a forensic neutral resolves the data-driven disputes at the center of large commercial litigation, from FRCP 53 authority to ex parte seizure relief. Daniel B. Garrie, Esq. https://tailoredmediation.com/insights/cyber-insurance-ransomware https://tailoredmediation.com/insights/cyber-insurance-ransomware Wed, 22 Jan 2025 12:00:00 GMT What cyber coverage actually buys in a ransomware event — first-party vs. third-party coverage, the war exclusion after NotPetya, and the OFAC risks of paying. Daniel B. Garrie, Esq.