Rule 26(f) Meet & Confer checklist

A stronger Rule 26(f) meet and confer 

The Rule 26(f) conference sets the tone for everything that follows in discovery. Walk in unprepared and you'll spend the rest of the case catching up. This checklist from Nextpoint's Client Success team covers every decision you need to make — before you're in the room.

Five reasons to download this checklist:

1. Think through the entire matter before discovery begins
   A structured walk-through of custodians, data sources, and collection scope forces you to identify gaps early — before they become expensive problems. Start discovery with a clear map, not a blank page.
   
2. Protect privilege from day one
   Decide upfront how privilege and confidentiality will be handled — including clawback terms under Rule 502. One conversation at the outset is far better than a dispute over inadvertent production later.
   
3. Reduce the scope — and the cost — of review
   Agreeing on keyword search terms, date ranges, and culling methods early can dramatically reduce the volume of data your team reviews. Smaller review sets mean lower costs and faster timelines.
   
4. Set production standards that actually work
   Metadata fields, file formats, native vs. image production, delivery method — these decisions matter. Get them locked in now so there are no surprises when productions land. Includes Nextpoint's recommended production specifications.
   
5. Build a discovery blueprint you'll use all case long
   A well-documented 26(f) plan isn't a one-time exercise — it's your reference point for every discovery decision that follows. Reduce disputes, stay organized, and get to the most relevant information faster.

Taking the time to prepare for the 26(f) conference is one of the highest-leverage things you can do for your clients. It makes ediscovery more efficient, reduces discovery disputes, and gets everyone to the most relevant information faster. Download the checklist.

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