WorkfloweDiscovery & Litigation Support

Production QC

eDiscovery production QC that runs each outgoing volume through five gates and keeps it locked until each stop is fixed, approved by a second person and signed off.

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Open the release gate and its nine screens ↓

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The problem

Volumes go out after a spot check that leaves no record behind

The volume comes off the review platform close to its deadline. Two analysts open a handful of images, eyeball the redaction boxes, scroll the load file in a spreadsheet and hope the Bates numbers run. Nobody reads under each box, and nobody can show afterwards what was looked at.

What slips past turns up on the other side: a box drawn as an annotation over live text, a text file taken before redaction, a document coded withhold after the log was served, dates that read as the wrong month. Each one brings a deficiency letter or a clawback, and if the firm cannot show reasonable steps, privilege can be lost.

Built foreDiscovery managersLitigation support teamseDiscovery analystsLitigation partners

The Problem Today

Once a privileged page or a live redaction reaches the other side, the firm must show what it checked.

576: documents clawed back from one production, privilege waived published

Checked by hand today

Privilege
Redactions
Bates
Load files

QC as a last-minute spot checkA slice of the images read by eye before the deadline
Nobody reads under the boxOverlays and stale text files keep the redacted words

The Solution

Each page through five gatesPrivilege, redactions, Bates, load-file fields, natives and image format
Read beneath each boxImage, text layer, text file and metadata; any readable word stops it
Each stop fixed, then approvedAn analyst fixes, a second person approves; nobody approves their own
Released after the signatureThe director signs a certificate of the steps taken on the volume

Built-in controls

Nothing leaves until each stop is cleared
Privilege calls stay with case counsel
Source metadata stays as collected

What You Get

Each volume leaves with a signed record of the steps taken, ready if a clawback is ever argued.

3 hours: of analyst time per 18,000-document volume, from about 16 our estimate

Log gaps drafted for counselWithheld documents missing from the log, each with an entry drafted
Gaps closed before sendingBates gaps and malformed dates fixed before opposing counsel sees them
Cover letter draftedWritten from the gates' results, sent only by counsel

Gate by gate

Nine screens of eDiscovery production QC, each holding one part of the release

One feature per screen, ordered as a production volume moves toward release, with the desk that uses it.

01Gate rules and roles
Gate rules read from the ESI protocol and protective order, per matter
How it works
- The ESI protocol and the protective order become each gate's rules, matter by matter
- 24 required fields, dates as MM/DD/YYYY, single-page TIFF at 300 dpi
- 63 privilege terms, 41 attorney names and 9 law-firm domains on the screen list
- All five gates block release, and a rule changes only with the project manager
eDiscovery project managerNo analyst keeps the protocol's field list and date format in a side note, and each volume of the matter is held to the same rules.
02Volumes in flight
A volumes board with a five-dot gate strip on every production
How it works
- Eight volumes across six matters, each with due time, documents, pages and analyst
- Five dots per row read clear, holding, running or could not read
- 237 stops holding 2 volumes, and 2 volumes due in the next 48 hours
- A load file the gate cannot read is flagged with its reason
eDiscovery analystSees which production is holding and why before opening any of them, with six matters' deadlines on one screen.
03Release gate, locked
A release gate that stays locked while any stop is open
How it works
- The volume flows through five gates, each with its passed count and what it holds
- 18,442 documents in, 235 stops at four gates, natives already clear
- A countdown to the deadline sits beside the lock
- The next step opens the gate with the most serious stop
eDiscovery analystKnows in one look what stands between the volume and its deadline, and which stop to fix first.
04Privilege gate
Withheld documents matched to the privilege log, missing entries drafted
How it works
- 18,442 produced documents screened against 63 terms, 41 names and 9 domains
- 187 hits, each already carrying a reviewer's call
- 1,418 coded privileged against 1,406 on the log: 12 missing
- An entry drafted for each from its metadata, for counsel to word
Case counselGets the unlogged documents in front of them with entries already drafted, before opposing counsel finds the gap in a deficiency letter.
05Redactions burned
A burn check that reads beneath every redaction box, layer by layer
How it works
- 2,316 boxes read in the image with the box lifted, PDF text layer, text file and metadata
- 9,264 reads, shown as one cell per box on a burn map
- 4 boxes on 3 documents still carry readable text
- Switching to x-ray shows the words found under the box
eDiscovery analystReplaces checking redactions by eye on the image, where a box drawn as an annotation or a stale text file still hands over the privileged words.
06Bates continuity
A Bates walk that finds each gap and traces why it happened
How it works
- Each number walked from first to last against its image
- 96,269 of 96,310 numbers have an image
- 3,912 families whole and 214 slip sheets on the log
- A 41-page gap traced to a deck re-coded after export began: re-export, no renumbering
eDiscovery analystFinds the missing images before a deficiency letter does, and knows why they are missing without digging through the export history.
07Load-file fields
Load-file dates checked against each email's own header and rewritten
How it works
- 18,442 DAT records checked against the 24 protocol fields
- 84 dates are impossible, with a month above 12
- 135 are valid but wrong, read with day and month swapped
- A preview sets each proposed date beside the native header, and the source stays untouched
eDiscovery analystNo more scrolling a load file in a spreadsheet, and no quiet dates that the other side would read as a different month.
08Who cleared each stop
Who found, fixed and approved each stop, kept on the volume
How it works
- Found by an agent, fixed by an analyst, approved by a second person
- Nobody approves their own fix
- Each clearance carries its time, above the full list of events on the volume
eDiscovery project managerKnows what stopped the volume, who fixed it and that someone else checked it, without chasing the team for answers.
09Release certificate
A release certificate that records each gate, its counts and its approvers
How it works
- Each gate with what it checked, its stops and who cleared and approved them
- The cover letter to opposing counsel drafted beside it
- Signing opens only once all 235 stops are cleared and approved
- The analyst releases by encrypted transfer after the director signs
Director of litigation supportCan hand a court a page showing the reasonable steps taken on this volume, rather than a story pieced together after a clawback.

Five gates on one 18,442-document volume held 235 stops, 219 of them dates

The volume as the gates first read it, a day before it was due.

Gate	Checked	Stops	What held it
Privilege	18,442 produced, 1,418 coded privileged	12	Withheld documents missing from the privilege log
Redactions burned	2,316 boxes on 1,148 documents	3	Readable text under 4 boxes
Bates continuity	96,310 numbers	1	A 41-page document numbered but never imaged
Load-file fields	18,442 records, 24 fields	219	Sent and received dates written day first
Natives and image format	1,284 natives	0	Nothing held
Release	Five gates	235	Locked until each stop is cleared and approved

Around the volume

Reruns, source lines and drafts around the production QC release gate

What the analyst and the project manager open between the gates and the signature.

Release gate rerun with each agent's result listed in turn: privilege hits, readable boxes, missing images, bad dates and natives passing — **The gates, run again**One click re-checks the whole volume and each agent reports in turn: 187 hits all reviewed, 4 boxes still readable, 41 numbers with no image.

Volumes board with a message for another matter: the load-file gate could not read a DAT encoded UTF-16 when the protocol asks for UTF-8 — **A load file it will not guess at**Another matter's DAT came encoded UTF-16 where the protocol says UTF-8. The load-file gate stops and says how to re-export it.

Source lines from the OPT file behind a citation: image paths for the gap and a note that 41 image files were not found — **The line behind the figure**A citation opens its source: the OPT lines pointing to 41 image files missing from the volume.

Twelve drafted privilege log entries with date, author and recipients, attorney-client or work product basis and a description, each marked drafted — **Twelve entries waiting for counsel**Each drafted entry carries date, author, recipients, privilege basis and a description, numbered on from the last log served, and stays a draft until counsel acts.

Redaction gate after the re-burn: the burn map with the fixed boxes in green and 0 characters read in each of the four layers — **Read again after the re-burn**After flattening, re-imaging and new text files, the same four layers are read again: 0 characters under each box.

Release gate with all five gates clear, each stop cleared and approved, and the lock open while the certificate waits for the director — **The lock open, one signature to go**With every stop cleared and approved, the lock opens. The one step left is the director's signature on the certificate.

What one volume would have handed the other side without the gates

Four things the gates found in one volume, each fixed before it could leave.

Privileged words on three documents

An email line on counsel's view of the indemnity cap, a memo prepared at counsel's direction and a draft reply with counsel's comments all read clearly. Two boxes were annotations over live text; the third document's text file was never regenerated.

Dates that look right and are not

One custodian's mail was processed with day-first settings. The 84 impossible dates stand out; the other 135 are valid dates in the wrong month, which a person scrolling the DAT would pass.

A deck numbered but never imaged

A board deck re-coded not privileged after the image export had started was numbered in the re-run of the volume. Its 41 pages had Bates numbers and no images.

Withheld, coded, and missing from the log

Twelve documents were coded withhold after the last privilege log was served. Reading produced images would never find them, because they were never part of the volume.

Counsel calls privilege, a second person approves, and the director signs

The agents check, match and draft. These steps stay with people.

Privilege callsCounsel decides what is privileged and words each log entry. The agents flag, match and draft.

Approving a fixThe analyst who fixes a stop cannot approve it. A second person does.

Adding or removing a redactionThe burn checker reads beneath boxes and reports what it finds. Re-burning is an analyst's step.

Changing source metadataCorrected dates go into a new DAT, and the native metadata stays as collected.

Changing a gate ruleA rule read from the protocol changes only with the project manager's approval.

Signing and releasingThe director signs the certificate and the analyst releases the volume. No agent sends a letter or a volume.

Before a volume leaves: questions on eDiscovery production QC

What is eDiscovery production QC?

eDiscovery production QC is the check a litigation support team runs on an outgoing volume before it reaches the other side. This solution runs each volume through five gates: privilege, redactions, Bates continuity, load-file fields, and natives and image format. The release stays locked until each stop is fixed, approved by a second person and signed off.

How can it tell a redaction is really burned?

It tries to read beneath each box in four places: the image with the box lifted, the PDF text layer, the extracted text file and the metadata. A box counts as burned only when all four come back empty. When one does not, the gate shows the words it found.

Does it decide what is privileged?

No. Counsel makes each privilege call. The privilege screen flags term, name and domain hits in produced documents, matches each withheld document to the log, and drafts entries for the ones missing, which counsel approves or rewords.

What does the release certificate show if a clawback is argued?

Each gate, what it checked, what it stopped, who fixed each stop and who approved the fix, with times, signed by the director of litigation support. It is the firm's record of the reasonable steps taken before the volume left.

Can the gates follow the ESI protocol in our matter?

Yes. The protocol reader turns the stipulated ESI protocol and the protective order into each gate's rules: the required fields, the date and time formats, the image format and which files go out native. A rule changes only with the project manager's approval.

Where do client documents stay?

Volumes and their gate records sit in the litigation support team's own workspace. Nothing from a client's volume trains a model, the QC evidence is held with the matter file, and each volume leaves by encrypted transfer, its key sent separately by counsel.

eDiscovery & Litigation Support