Digital White Papers

72 WWW.ILTANET.ORG | ILTA WHITE PAPER LITIGATION AND PRACTICE SUPPORT Managing Incoming Document Productions Strategically live without color email. Will you want to use technology-assisted review to thread emails? Emphasize obtaining email fields like conversation index. Be mindful of proportionality: a request for 50 metadata fields to an individual plaintiff represented by a small firm will either be disputed or ignored. You will also need to be conscious of the burden of providing the same metadata fields for your own data. If you are involved in a large joint defense group, you may be compromising with multiple firms on a format that works for everyone. On large ongoing maers where you will be receiving productions in a series via file transfer protocol, especially email links, it is great if someone from litigation support or your service provider can be added to the distribution list for productions. Waiting around for an aorney to forward you a password leads to premature aging! Receiving and Loading Productions A lile project management will go a long way to keep things organized once you start receiving documents. Whether you use Excel or a sophisticated project management tool, keep a record of every production tracking producing party, production volume, Bates range, date produced, format, location of original media, encryption key, etc. A link to the production's transmial leer or email is a great addition to your index or database. When your records are loaded into your review platform, use folders, tags or fields to track the producing party, volume and date. It is a time-saver if users can tell at a glance when any particular document was produced without checking a production log or looking for a cover leer. Educate your aorneys and paralegals where to find the produced documents, especially if they are kept in the same database with non-produced client documents. It can be useful to have a staging database for loading productions to make sure you are not corrupting your main database. If your case teams are eager to look at documents but you are having issues with the load files — or your database is hosted and loading may be delayed — have a PDF utility ready to make a set of PDFs for aorney review. If you have an old copy of Concordance or similar program on hand, you can quickly put together a separate local database to validate the load files and find any documents needed right away. Before you begin loading the production, take a look at what you received. We try to download, extract, or copy the load files before the images so we can begin investigating right away. Even if they are turning over a production to a service provider for loading, most firms I have spoken to will do an initial review. Joan Washburn of Holland and Knight says, "Whether we outsource or not, we always at least evaluate the load file to make sure there are no obvious issues, and QC to make sure image counts match. If we don't do so, the cost is already incurred and it's a lot harder to put that genie back in the bole. If we find an issue, we alert the case team and they then make a decision about how much to fight the other side for a corrected, non-deficient production." Be mindful of proportionality: a request for 50 metadata fields to an individual plaintiff represented by a small firm will either be disputed or ignored.

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