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Discovery Production Organization Checklist

Productions get expensive when organization is treated as a post-review chore. This checklist sets the conventions before a single document is reviewed — naming, numbering, custodian tracking and privilege logging — so the production is defensible and the second request costs a fraction of the first.

Who it's for
Civil litigation, commercial litigation, employment and insurance defense teams.
Bates-numbered document sets, custodian logs and a privilege log spread across a litigation workroom table

Before collection

  • Written scope: custodians, date range, systems, file types
  • Preservation notice issued and acknowledged, with the acknowledgment retained
  • Search terms agreed or documented, with the reason for each
  • Format of production agreed in writing (native, TIFF plus text, or PDF)
  • Bates prefix, starting number and confidentiality designation convention fixed in advance

Collection tracking

  • Custodian log: name, role, systems collected, date collected, volume
  • Source log for third-party productions, with the request that produced them
  • Chain-of-custody notes for any physical media
  • Exception log for corrupt, encrypted or unprocessable files

Review organization

  • Responsiveness, privilege, confidentiality and issue tags defined before review
  • Family relationships kept intact — attachments never split from their parent
  • Duplicate and near-duplicate handling documented
  • Redaction protocol: what is redacted, under what basis, and how it is labeled
  • Second-pass quality check on every privilege call

Privilege log

  • Date, author, recipients, copyees, document type and general subject
  • Privilege asserted and the basis for the assertion
  • Bates range or control number for each withheld or redacted document
  • Consistent treatment across families and across custodians

Production package

  • Production volume named and dated, with the Bates range recorded
  • Load file validated against the images and text before delivery
  • Confidentiality legends applied per the protective order
  • Cover letter identifying volume, Bates range, format and any withheld categories
  • Internal production log so a later volume never re-uses numbers

Practical notes

  • • Fix the Bates convention first. Renumbering after review is the single most avoidable cost in a document production.
  • • A production log that survives an attorney's departure is worth more than a perfectly formatted cover letter.
  • • The producing attorney owns every responsiveness and privilege determination.
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Confirm the scope in writing, pay the flat fee, sign the service agreement, complete the matter intake, then upload your records to the secure vault. Preparation begins when the file is complete.

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