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Incoming Production Analysis

Incoming production analysis that reads each volume the other side serves, finds the custodians, months and requests it leaves out, and drafts the letter with Bates cites.

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The problem

A custodian count that looks complete can hide a mailbox gone quiet

When a volume lands, the analyst runs saved searches and pivot tables in the review platform: counts by custodian, a date pivot, search-term hits, a family check. The associate reads the reports between depositions. A custodian whose own sent mail stopped for three months still shows thousands of documents, because the mail other people sent her is there.

So the hole surfaces in a deposition or at trial, long after the cheap moment to raise it has passed. By then it costs a motion, a re-production and a second review of documents the client already paid to review once, and a late letter makes a thin record that the firm tried to confer first.

Built forLitigation partnersSenior associatesLitigation support analystsDirectors of litigation support

The Problem Today

Checking what the other side served against what it owes is still pivot tables and saved searches, rebuilt by hand for each volume.

73%: of what producing electronic documents costs goes to review published
30 days: to answer requests, and objections must say what is withheld published

Checked in pivot tables today

Custodians
Date ranges
Requests
Attachments

Letters that miss the windowThe deficiency letter goes out weeks after the volume lands
Analysts on pivot tablesHours of counts, date pivots and hit lists for each production

The Solution

Custodian by monthEach volume mapped from its load files: whose mailbox, which month
Silent mailboxes foundMail others sent each person, set beside what their own mailbox holds
Each request checkedCovered, thin or answered by nothing, beside the other side's response
Cited letter, signedEach gap goes in with its Bates numbers; the partner signs and sends

Built-in controls

Nothing reaches opposing counsel unsigned
Received volumes stay read-only
Every load, decision and signature on the audit log

What You Get

Deficiencies are raised inside the window, each with Bates numbers the other side can check.

3 hours: of analyst time per production, down from 20–30 our estimate

Missing custodians namedNamed people whose mailboxes did not arrive
Quiet months explainedOut-of-office replies and duplicates ruled out first
Unproduced attachments listedEach memo the mail cites that no volume holds

From load file to signed letter

How incoming production analysis finds what the other side left out

Nine features, set out as a received volume gets worked: load file, heat map, gaps, custodians, requests, missing attachments, then the letter the partner signs.

01Incoming volumes
Each volume read from its load files, with Bates breaks found before review
How it works
- Every volume logged with its documents, pages, Bates range and custodians
- Load-file checks on arrival: agreed fields, Bates continuity, families, deduplication, dates and text
- 41 of 41 agreed fields present, AllCustodians among them
- A 178-page Bates gap with no slip sheet, flagged as the volume loads
Litigation support analystLearns whether a volume is usable as it lands, with no counts or date pivots to rebuild for each production.
02Custodian by month
A heat map of every named custodian by month, with unproduced columns empty
How it works
- One column per custodian named in the ESI protocol, one row per month of the agreed range
- Each cell counts documents from that custodian's own mailbox
- The 2 custodians not produced show as empty, struck-through columns
- Cold cells mark months a mailbox goes silent while others keep writing to it
Senior associateSees on one screen what the other side left out of 61,000 documents, where saved-search reports read between depositions never showed it.
03A cold column
A silent mailbox caught by the mail other people kept sending to it
How it works
- Sets mail sent to each custodian beside documents from their own mailbox
- The VP of Sales: 212 emails to her over three months, none from her mailbox
- 19 replies quote messages she sent then, and none of the originals is produced
- Duplicates, out-of-office replies and a change of job ruled out before it is called a gap
Senior associateA count by custodian showed thousands of her documents. This shows the three months that are missing, and why they are not duplicates or a holiday.
04Date gap, week by week
Each date gap drawn week by week, with the checks run before it is called
How it works
- Her mailbox's documents as bars, other people's mail to her as a line
- 13 weeks with nothing from her mailbox, while 212 emails reach her
- 5 of the 212 shown from other people's mailboxes, each with its Bates number
- Put in the letter, dismissed with a reason, or sent back to the analyst to check
Senior associateCan defend the gap at the meet and confer, because each check behind it is on the screen with the page it rests on.
05Custodians
Named, produced and seen in the mail, three custodian lists side by side
How it works
- 16 named in the protocol, 14 mailboxes produced, 2 missing
- The two missing custodians appear in 2,034 produced emails between them
- Deduplication accounted for through the AllCustodians field before anyone is called missing
- A sales manager nobody named turns up in 2,104 emails, ready to propose
Litigation support analystShows a custodian is missing, and not merely deduplicated, with no custodian fields exported to a spreadsheet and sorted.
06Coverage by request
Every request for production marked covered, thin or answered by nothing
How it works
- Each request mapped to its custodians, its date window and the documents that answer it
- Of 48 requests: 33 covered, 6 thin and 9 with nothing produced
- The other side's written response sits beside each request
- Request 7 was promised, and its agreed terms hit 0 documents in the window
Senior associateFinds the requests the other side agreed to answer and then left empty, before the time to raise them runs out.
07Hot documents
Hot documents flagged, and each cited attachment no volume holds listed
How it works
- Flags hot documents while it profiles: 23 in this production
- Each document the mail cites but no volume holds, such as a pricing memo cited in seven emails
- 41 missing attachments, 17 broken threads and 1 Bates gap gathered into one schedule
- Nothing counts as hot until the associate confirms it
Senior associateTurns the memo everyone mentions and nobody produced into a specific ask, cited to the email that mentions it.
08Drafted paragraph
A letter paragraph drafted from the finding, with the quoted replies cited
How it works
- One click on a finding drafts its section of the deficiency letter
- Two produced replies cited by Bates number as examples
- Names the protocol section the custodian falls under and asks for her email or a written reason
- The finding moves into section B, waiting for the associate's approval
Senior associateStarts from a cited paragraph rather than a blank page, and no Bates number is retyped out of a report.
09Signed deficiency letter
Letter sections approved one at a time, then signed by the partner
How it works
- The associate approves each of the five sections, A to E, separately
- The analyst who loads volumes cannot approve or send
- Only the partner signs and sends to opposing counsel
- Signed 2 days after the volume arrived, with 12 days of the 14-day window left
Litigation partnerSigns a letter with each gap cited, inside the window the protocol allows, so the record of conferring is there if a motion follows.

Four finds a custodian count by itself would pass over

Four findings from one volume, each decided by the associate before the letter went out.

Replies that quote her missing mail

Nineteen produced replies quote messages the VP of Sales sent in her silent months. No original is in any volume, and the AllCustodians field never names her for the 212.

A memo cited seven times

Seven produced emails cite a pricing memo that holds back 20% of the client's allocation. It is in no volume, so it goes into the letter's schedule.

A central person nobody named

A sales manager outside the protocol appears in 2,104 produced emails, more than any named custodian. The associate can propose him as an additional custodian.

Objections that stay silent

Two of the nine empty requests drew objections that do not say whether anything is withheld. The letter asks for that statement in writing.

Around the findings

The grid's other layers, the cited pages and the quiet months explained

What the analyst, the associate and the partner open around the findings.

Heat map layer of emails sent to each custodian by month, including the two custodians whose own mailboxes were not produced — **Who kept writing to whom**The same grid, switched to mail others sent each person. The two custodians not produced still fill their columns here, which is how they show up as missing.

Custodian heat map with request 44 laid over it as a hatch across five custodians, three cold cells and two missing columns inside it — **One request laid over the grid**Request 44 expects 5 custodians. Inside its window sit 3 cold cells and 2 custodians not produced, and 0 documents answer it.

Produced email opened from its Bates citation: a reply from a sales lead quoting the instruction the VP of Sales sent the evening before — **The page behind the cite**A click on any Bates number opens its produced page. This reply quotes an instruction the VP of Sales sent the evening before, and her original is in no volume.

Monthly chat chart for the director of pricing with two empty months, and the recommendation to include it in the letter as a narrow ask — **Chat that stops while email goes on**The director of pricing's chat drops from a monthly average of 81 to 0 for two months while his email continues. The pattern fits an export that stopped.

Date gap for the VP of Operations marked explained: 62 documents in December against a median of 249, covered by 38 out-of-office replies — **A low month, already explained**The VP of Operations has 62 documents in December against a median of 249, and 38 out-of-office replies cover the holidays. It stays out of the letter.

Audit log for the matter: the volume loaded, six agents' steps from profiling to drafting, and two earlier letters signed by the partner — **Every agent step, on the record**Each agent's step beside who loaded the volume and who signed the last two letters. The log stays on file until the matter closes, then 7 years more.

Three volumes, 61,000 documents and 234,597 pages, from 14 of 16 custodians

What the other side served under the protocol. Each volume added custodians, and the last still left two out.

Volume	Documents	Pages	Custodians
First	8,412	31,604	6
Second	19,950	74,880	11
Third	32,638	128,113	14
All three	61,000	234,597	14 of 16

The associate decides each finding, and only the partner sends

Agents profile, reconcile and draft. These calls stay with the lawyers.

Whether a gap goes in the letterThe associate includes it, dismisses it with a reason kept on the record, or sends it back to the analyst to check.

Whether a document is hotAgents flag. A person confirms before anything is marked hot or privileged.

Why something is missingThe agents report what is absent and what they checked. Intent is left to the lawyers.

Whether a thin request mattersThin coverage goes to the associate as a judgment, to include or leave out.

What reaches opposing counselThe partner signs and sends. Agents never contact the other side and never change a received volume.

Incoming production analysis, asked by litigation partners and analysts

What is incoming production analysis?

Incoming production analysis checks what the other side produced against what it owed: each custodian named in the ESI protocol, each month of the agreed range, each request for production, and intact families and Bates numbers. Some teams call it inbound production analysis. This solution runs it on each volume and drafts the deficiency letter.

How do you tell if opposing counsel's production is incomplete?

Compare it against the protocol and the requests, then look past the counts. A custodian count alone hides a mailbox that went quiet, so this sets the mail others sent each person beside the documents from their own mailbox, and checks replies that quote messages nobody produced.

Does it write the discovery deficiency letter?

It drafts one, section by section: each gap with Bates examples, the protocol section it falls under, and an ask with a date. The senior associate approves each section, and the litigation partner signs and sends it.

Could a missing custodian just be a deduplication effect?

It could, which is why the AllCustodians field is read before anyone is called missing. A custodian counts as not produced only when no volume lists them as custodian or in AllCustodians, while they still appear in the produced mail.

Does it explain quiet months that are not gaps?

Yes. Out-of-office replies, leave dates and departure dates are checked before a month is flagged. A holiday drop that matches out-of-office replies is marked explained and kept out of the letter unless the associate changes it.

What happens to the other side's documents?

Received volumes are read-only, held under the protective order in a workspace the firm controls. They never become training material for any model, and each load, analysis, decision, signature and send is audited.

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