No matter how many times a litigator takes a new matter, some new wrinkle or challenge will interfere with their plans.
Next month, Nextpoint will introduce our Client Success Summer Camp, a free, three-part webinar that will offer all of the tips, workflows, and guidance you need to manage any matter from start to finish. I will be presenting the second session on document review strategies on July 24.
What’s Your End-Game?
At the start of any document review process, your team needs to have an end goal in mind. That is, you should know the due date of your production, and the specifications for that production. That means knowing your file formats, conversion costs (if necessary), and any technical complications.
At Nextpoint, we counsel our clients to set a “pencils-down” review deadline with enough cushion to to give yourself some breathing room to allow for contingencies.
Special considerations include:
- How will you split up your documents for an organized review?
- How will you handle producing non-imageable files?
- What custom coding fields will you need to organize your documents?
- What are the Bates numbering and confidentiality stamping requirements?
- If opposing counsel produces bulk PDFs or other unwieldy documents, can you split them?
Reviewing Smarter, Not Harder
Importing and getting documents set up for review ought to be a simple and automated process. Emphasis on ought. After doing this kind of work for many years I can tell you that there are always quirks and complications found in any document collections. Something as simple as a document that has blank pages or no information can upset even the best laid litigation battle plans.
On the 24th, I will walk through some of the most important, and hard-learned quality control lessons I’ve learned, including:
- Divide your documents up in a logical way to approach your review (e.g. by custodian, by date range, by keywords, etc.)
- Split bulk PDFs so they can be reviewed as individual documents
- Keep emails and attachments together for review and production
- Export a .CSV load list you are going to produce, prior to Bates stamping for quality control
- Run search to make sure each document has a Bates stamp prior to production
I hope this gives you a sense of the broad issues to be considered in your initial negotiations with opposing counsel in any matter. As mentioned, you can sign up for our webinar series to get more details and downloadable materials. The entire series will also include strategies for meet and confers and tips to prepare for your next trial or hearing.