eDiscovery Daily Blog
Other Production Parameters from a Provider’s Point of View – eDiscovery Best Practices
Yesterday, we began to discuss some of the production parameters that CloudNine Discovery collects from our clients in order to ensure that the production includes the correct documents in the required format. But, wait – there’s more! Let’s take a look at some other examples of information we collect from our clients.
- Naming Structure for Files: Files that are produced follow some sort of naming convention and structure, typically either the original file name or some sort of naming convention that involves a unique identifying prefix followed by a zero-filled number (e.g., ABC000001.{file extension}).
- Image Endorsements: Of course, images that are produced typically include a Bates number on each page that involves a unique identifying prefix followed by a zero-filled number (see example above), but endorsements can also include special endorsements such as a confidential stamp, so we provide a place on our questionnaire for clients to provide additional endorsement instructions for text and placement.
- Metadata Fields and/or Tags to Be Produced: If the client is producing metadata, it’s obviously important to know the fields to be produced and the desired order. We also ask them to specify the delivery format – the typical formats are CSV (comma separated values, which can be loaded into Excel) or DAT (data) file.
- Populate Production Numbers Back into Database: When clients produce documents, they typically want to track the production numbers, so we give them the option for us to create new fields in their (OnDemand®) database with those production numbers.
- Branded Images Back into Database: We also offer the same option for putting images branded with the Bates numbers and other endorsements back into the database, so that the client can easily reference the production number when looking at the page.
- Load File: Often parties agree to produce load files to make it easy for opposing counsel to load the documents and metadata into their own eDiscovery platform, so we will create load files in several industry standard formats to support that requirement.
- Delivery Method for Production: There are several options for delivering documents and data including CD or DVD, portable hard drive or electronically via File Transfer Protocol (FTP).
- Where to Send Production: If the client selects CD, DVD or Portable Hard Drive, we require the Name, Street Address and Phone Number where the media is being delivered, if they select FTP, we need an FTP address (and any credentials, if necessary, to access it).
- Name of Production Set: We request that each production set be uniquely named for later reference purposes, which is especially useful when there are multiple productions to track.
- Other Instructions: Believe it or not, all of the parameters that we’ve identified over the past two days don’t cover every scenario, so we provide a place on the questionnaire to provide any other instructions. Those can range from special handling for other file types, extra copies requested, etc.
As you can see, we collect a lot of information from our clients at production time to ensure a proper production. There are a lot of variables to consider, so it’s important to be consider those variables not just when producing, but WAY back at the beginning of the case, to ensure that you will be able to fulfill your discovery obligations to opposing counsel. Hope this list of parameters was helpful.
So, what do you think? How do you ensure proper productions? Please share any comments you might have or if you’d like to know more about a particular topic.
Disclaimer: The views represented herein are exclusively the views of the author, and do not necessarily represent the views held by CloudNine Discovery. eDiscoveryDaily is made available by CloudNine Discovery solely for educational purposes to provide general information about general eDiscovery principles and not to provide specific legal advice applicable to any particular circumstance. eDiscoveryDaily should not be used as a substitute for competent legal advice from a lawyer you have retained and who has agreed to represent you.