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Document Productions - Gain without Pain

Tips for Managing Document Productions

For full details, download Erika’s paper available at the end of this blog post.

Document productions can be painful. Time is rarely on your side, there’s a very low tolerance for error, and surprises can pop up out of nowhere causing all kinds of headaches. As we saw with the Wells Fargo eDiscovery debacle a few months ago, a production misunderstanding or misstep can be a recipe for disaster.

What can you do to help ensure your productions will run without a hitch? If you’ve read my two prior blog posts on processing and hosting, you probably know the most important answer: Be prepared with the necessary matter knowledge, the ESI protocol and a well-considered execution plan from the very beginning of the project. After that, all you have to do is stay the course — with enough flexibility to make any necessary adjustments along the way.

Here’s a summary of some tips that may help, but for full details, download the paper available at the end of this blog post.

#1  Know the ESI protocol like you know your own name.

This is hands-down and unequivocally the most important rule of all when it comes to managing successful productions. In fact, it’s the rule that should have been on your mind from the beginning – all the way back through collection and processing.

Decisions about how and what to collect as well as processing options such as deduplication, embedded-object handling and extracted metadata, all come into play at the production stage. If you’ve taken a wrong turn early on, you may not encounter the repercussions until it’s too late, resulting in a credibility problem if you ask for accommodation, or a costly course change if you try to switch gears late in the game.  For example, what if embedded objects were supposed to be extracted as separate files rather than rolled up with their parent file? Going back to reprocess and reconcile these files is not something you want to deal with when there’s a production deadline looming.

But let’s assume you’ve followed a sensible ESI protocol during collection and processing. Great! You’ve likely avoided some major hassles. This isn’t the time to let loose the reins, though. That protocol is still your roadmap for production as well, and it will see you through to the end.

#2 Use targeted workflows and focused reviewer configurations.

Set up multiple levels of review, not just first pass and privilege. Targeted workflows for redaction, conflict resolution, and QC are crucial components. The key here is to keep reviewers focused on as few objectives at once as possible—this helps them move through documents faster while maintaining better levels of accuracy in coding. And keep coding panels simple, as too many options are distracting and you’ll lose the edge you gained by separating your review streams in the first place.

Ensure there is no possibility for reviewers to step on each other by working on the same document for the same coding purposes at the same time. Create a simple and easy-to-use strategy of selecting and viewing document sets for review.

#3 Take advantage of dynamic searches and automation.

Save time by creating dynamic saved searches to identify different review populations, and then use those to feed imaging and automated batching. This has the added benefit of keeping everyone informed about production readiness.

A good approach is to create a search for every review stream and then use an automatic batching schedule to keep reviewers busy. All document families with no coding go to first pass, those with responsive coding and a privilege indicator move on to focused privilege review, anything with a “to be redacted” flag goes into the redaction application bucket, etc.

You can apply the same strategy to identifying coding conflicts and redaction issues. Create dynamic saved searches to target families with inconsistent coding (like responsiveness or privilege coding, for example), as well as trap documents missing their redactions before they can be inadvertently sent out the door. Use these “safety nets” to feed views, and/or dashboards to ensure clear insight into production readiness (or “un-readiness”) across the full population. This allows you to tackle challenges early so that there are no surprises (and no additional spend to fix avoidable mistakes).

#4 Use analytics.

At a minimum, apply email threading and near-dupe identification. Grouping threads and similar documents for reviewers increases accuracy as well as speed. Not only will reviewers get through documents faster, but you’ll spend less time tracking down and correcting inconsistencies in coding. Clustering is also a great way to go if you have a significant portion of non-email data. You can organize review sets based on clusters (instead of threads) for the same benefits.

Bottom line…

Your ESI protocol is your best friend for the duration of a matter — it’s the foundation of your success. The more attention you pay to the protocol early on, the better.

So, spend time at the beginning formulating the plan and then follow it – but be prepared to be flexible, as things may change. Leverage common sense and the best tools you have at your disposal and you just might make it to production unscathed.

For details about this topic, download Erika’s paper, Document Productions: Gain without Pain by clicking here.


This post is third in a series by Erika Namnath about eDiscovery services.  See eDiscovery Processing: 7 Tips for Reducing Stress (and Spend)and  eDiscovery Hosting: Tips for Running Lean and and Mean with Hosted Workspaces.  


Erika Namnath joined H5 in August 2005 and is Associate Director of Technical Services within the eDiscovery Group. She focuses on litigation support services including media management, processing, imaging, and production. She has designed and implemented strategies for a variety of use cases, including data reduction and subjective culling, responsive review, expert search, and workflow prioritization. 

Erika will appear at Relativity Fest, presenting Conquering Your Productions—Take Charge Like a Boss!” Register and join her session!  And H5 is competing for an Innovation Award, so stay tuned!

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