Production

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Loading Data into Your Internal Database

When you receive a production of documents you may receive any combination of images, full extracted text, OCR, native files, extracted fields including metadata, along with a load file to define document breaks and relationships between emails and attachments. The load file will also facilitate the uploading of the production into your litigation support database application. As discussed above, it is important to review the production with a view to completeness and compliance with the agreed-upon technical requirements. When loading the data into your internal database – whether data produced to you or data produced by you – it is important to keep in mind considerations to prevent alteration of the data you have received and to facilitate the efficient review by the legal team. Those considerations might include:

  • Capture source and all identifying information in fields in your database (e.g. the document request to which the subject production is responsive; producing party; date of production).
  • Lock down extracted data and metadata fields that are produced by other parties so data is not altered by the legal team. Some options might include:
    • Create a shadow field to include the extracted data and metadata fields that can be edited by your legal team. For example, the date of a document according to the extracted data or metadata is 00/00/0000. When the document is reviewed, it is evident that the document date is actually 01/29/1999. Edit the date in the shadow field, not in the original extracted data or metadata field.
    • Hide and lock the extracted data and metadata fields so the legal team will only see the shadow metadata fields that are editable.

If there are problems with the load files that you receive you must know how much time is reasonable to attempt to resolve those problems. Do not invest more time than that. Remember your client will be paying for your time to fix something that possibly should be fixed by the producing party. Do not be tempted to spend a lot of time modifying load files to make them work. On the other hand, if there is a quick fix, it may well be worth the time to fix it yourself in order to have the production up and running for your legal team as quickly as possible. If you do find that it is necessary to modify the load file, communicate with the lead attorney about the problems so a specific request for a workable load file can be made of opposing counsel for future production.

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Negotiation Considerations

Communication within Your Team

Form of Production

Evaluation of Production Files

Loading Data into Your Internal Database

Hosting Data

Production History Log

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