DISCOVERY
Discovery is a pre-trial procedure where either parties to a suit obtains evidence from the
other by way of request for answers to interrogatories or request for admission, or request
for production of documents, etc.
DOCUMENT REVIEW PROCESS
The document review process involves reviewing and analyzing to determine what
documents must be withheld from production to opposing counsel. The review process
often consists of the following:
Responsive/ Relevancy Analysis
Identifying the documents pertaining to the subject matter
or issue at hand.
Privilege Analysis
Documents are reviewed for Privilege information Attorney Client Privilege, Attorney Work Product or Joint
Defense Claims, AC or WP compilation.
Privilege Redaction
Redacting specific portions of documents that are identified
as privileged content.
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Hot/Warm
Responsive documents tagged as hot or warm if the
information/document is found to be vital to the issue at
hand.
Confidentiality Review
Responsive documents
reviewed
for confidential
information- e.g. financial, pricing terms, agreements with
confidential clauses, personal information.
Privilege Log
Documents that are withheld from production is described
by drafting a Privilege Log.
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REVIEW FLOW CHART
DOCUMENT DATA BASE
ASSIGNMENT OF BATCHES TO REVIEWERS
RESPONSIVE
NON-RESPONSIVE - DONE
PRIVILEGE REVIEW
PRIVILEGE
WITHHOLD
PARTIALLY PRIVILEGE - REDACTIONS
ATTORNEY CLIENT PRIVILEGE
OR WORK PRODUCT
NOT PRIVILEGED
CONFIDENTIALITY REVIEW
APPROVAL OF PRIVILEGE
DOCUMENTS BY CLIENT
CONFIDENTIAL, HIGHLY
CONFIDENTIAL, PUBLIC/NONDESIGNATED
PRIVILEGE LOG
HOT AND WARM DOCUMENTS
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INTERNAL PROCESS
Project plan tailored to the specifications of
client/counsel and consistent with best
practices.
Training on Client Review Platform
(Dummy)- Team gets accustomed to the
platform.
Team understands the protocol and
background facts of the litigation.
Receipt of review protocol and RFP
materials from the Client.
Training session by the client (Remote).
Clarifications, if any are made during the
training session.
Comprehensive internal floor training on
the RFP, review protocol and platform.
 Clarifications, if any are made during
Internal team discussion on the scope of
the training session.
review and types of documents ensuring all
reviewers are on same page.
Initial review carried out at a slow pace in
order to be familiar with the subject matter
and documents.
Test initial review work product using
sampling, specific re-review, and
validations searches. QC and Delivery.
Calibrate initial review results, elevate
queries regularly and update the review
protocol accordingly and seek approval of
same from the counsel/client.
Project completion as per TAT
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Deliver regular, comprehensive reports to
monitor progress and quality and to assist
client in managing the review process.
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