Production - Production History Log

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Production
Negotiation Considerations
Federal Rules of Civil Procedure
Factors to Consider
Metadata
Rolling Production
Production Media Types
Communication within Your Team
Form of Production
Paper
Quasi-Paper
Quasi-Native
Native
Evaluation of Production Files
Loading Data into Your Internal Database
Hosting Data
Volume of Data
Who Will Need Access to Data
Production History Log
Additional Materials
Participants

It is very important to document the history of document productions, both paper based and electronic based. Every piece of media should be tracked as it moves through the processing and discovery process by each person or company handling it. The preservation and documentation of chain of custody is discussed in the Collection Node. However at the production stage it is equally important to maintain a production history log. Traditionally, this type of log has been kept by paralegals and that tradition can continue. It is important that the electronic productions are tracked the same way as non-electronic productions and it is best that there be a single point of contact for this information, be it a paralegal, an attorney, or someone in the litigation support department.

Consider including the following information in a production history log:

  • Date sent
  • Sent to (include full contact information)
  • Means by which sent (include tracking info)
  • Description of media sent
  • Bates range of production
  • Location of copy of media sent
  • Document Request to which production is responsive
  • Comments

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