- Before
- “The return date is in my calendar. Whether request seven is actually answered is in nobody's.”
- Now
- Works the docket with the agents: approves their search plans and in-scope reruns, and sees each request's thread from scope to Bates.
One subpoena, from service to a signed production
Harmon & Vale LLP serves a Rule 45 subpoena on Kestrel & Vane Logistics LLC through its registered agent on Thursday 15 October. Kestrel & Vane is not a party to Brightwater Cold Chain v. Delmar Freight Holdings in the Northern District of Illinois, but Delmar hauled its refrigerated freight from 2021 to 2024. The agents do the reading, clocking, holding and searching, and say what they found and what they did not. Maya Ferreira, the subpoena coordinator, approves each step, and Priya Natarajan, litigation counsel, signs. Here it is, screen by screen, in the working solution.
- 01Wednesday 28 October, morning
Every open demand on one docket, with its live clock
Maya Ferreira · Subpoena coordinatorMaya's docket holds 22 open demands: 5 due in 7 days, 3 at risk and 3 waiting on counsel. Subpoenas, police and grand jury requests, court orders, agency demands and preservation letters sit in one list, each with its days left. 2026-SUB-0418 is 6 days from its return date. Its nine requests run down the page, each threaded from scope to custodians, hold, search, review, redactions and Bates. Eight are complete. Request 7, communications with Delmar, is broken at the search.
“Nine requests, each threaded to what answers it · 8 of 9 answered · 1 broken thread · click any bead for its evidence.”
- 02One click on a clock
The objection date, with the rule it came from
Intake agentThe subpoena was served Thu 15 Oct at the registered agent. Under FRCP 45(d)(2)(B), objections are due before the earlier of the compliance date and 14 days after service. Day 14 is Thu 29 Oct, a normal court day, and the compliance date is Tue 3 Nov, so 29 Oct governs. The trace shows Priya served on Tue 27 Oct at 16:22, two days early, and that the clock warns 3 business days ahead and alerts at 1.
“Computed by the intake agent from the rule library and the court's holiday calendar. Every change to a clock is on the audit trail.”
- 03Thursday 15 October
Accept, narrow or object, with the burden measured
Scope agent · Priya Natarajan, litigation counselThree minutes after the intake agent read the subpoena, the scope agent split it into nine requests and drafted objections to requests 6, 8 and 9. Each request shows its hits, pages, reviewer-hours and measured burden. Request 2, invoices and payments, is 1,904 hits, 1,140 pages and $1,140. At the meet and confer on 22 Oct, Priya and Harmon & Vale agreed to narrow request 6 to the minutes that mention Delmar and to produce request 8 Attorneys' Eyes Only. Harmon & Vale did not withdraw request 9.
The scope agent never serves an objection. Priya signed on Tue 27 Oct at 16:10, and the objections went out by email and overnight courier at 16:22.
- 04Friday 16 October, 08:12
The hold goes out before anything is searched
Preservation agentHold HN-2026-0418 goes to seven custodians with a six-question questionnaire, and all seven acknowledge by Mon 19 Oct. Retention is suspended in seven mailboxes, Teams, the Carrier Management site, the ERP payables archive purge, the transport system's 36-month purge and the claims system. The answers become search terms: Sanjay Iyer gives vendor 118842, and João Pereira says DMF is the carrier code in the transport system.
The search agent cannot start until the hold is acknowledged, and only litigation counsel can release a hold.
- 05Monday 19 October
A search plan she approves, and an honest list of gaps
Search agent · Maya FerreiraThe search agent shows its plan per request (sources, custodians, terms and dates) before it runs. Maya approves it at 15:10, after the hold. It gathers 18,692 items from 7 sources, 5,999 after de-duplication, and 1,165 responsive. Request 9 is not searched, because the objection stands. Maya asks in plain words what it did not find.
Search agent: “Four gaps. Request 7, 2021 to mid-2022: Ruth Okafor has almost no emails with the carrier in those six quarters, but payables shows 31 payments to ‘Del Mar Freight Lines’. The QC agent has flagged it.”
- 06Monday 26 to Tuesday 27 October
Each document beside the agent's reading of it
Redaction agent · Maya FerreiraThe review shows three panes: the queue, the document with its proposed redactions, and the agent's summary. A Q4 2023 lane review from Tessa Ashby answers request 5. It is marked responsive with no counsel on the thread, and two other carriers' rates are blacked out on the objection to request 9, FRCP 45(d)(3)(B)(i). The redaction agent proposed 297 redactions on 90 documents, each with its authority. Maya accepted 1,165 first-pass decisions.
No redaction is burned in until a reviewer accepts it. Lifting one asks for a reason, and the override is logged.
- 07Wednesday 28 October, 09:31
Request 7 is not answered, and here is why
QC agentThe QC agent checks the search against three signals it did not use. The vendor master lists the alias “Del Mar Freight Lines”, domain delmar-fl.com. Payables shows 31 payments to that name from January 2021 to June 2022. And Ruth Okafor's hold questionnaire, returned the night before and eight days after the search ran, says “they were Del Mar Freight Lines until mid-2022”. The subpoena's Definition 3 includes predecessors, so these emails are inside request 7.
QC agent: “Same request, custodians and dates: I can rerun without widening the scope.” Confidence 0.94.
- 08One approval
She approves a rerun inside the agreed scope
Maya Ferreira · Subpoena coordinatorThe rerun keeps the same request, the same four custodians and the same dates, 1 Jan 2021 to 31 Dec 2024. It adds “Del Mar”, @delmar-fl.com and the shared mailbox dispatch@, and expects about 210–230 emails. Maya clicks “Rerun within scope”. The search, review, privilege and redaction agents run again: 212 new emails, all responsive, none privileged, 14 redactions on 6 emails. Request 7 now holds 868 documents and 1,312 pages, and all nine threads are complete.
“Inside scope. Rule S-2 lets the coordinator approve this; anything wider goes to counsel.”
- 09Before release
Nine gates, a second read, and her signature
Priya Natarajan · Litigation counselThe QC agent re-reads the production against every request. It runs a second privilege screen (0 new privileged), checks that 311 of 311 redactions cite an authority, and confirms Bates continuity from DEL-000001 to DEL-004386 with no gaps. Eight gates are green, and the ninth is Priya's sign-off. She sees 1,377 documents, 4,386 pages, 23 withheld and 311 redactions. She chooses “Approve as produced”, ticks the attestation and types her name.
“I have checked the gates and the privilege log; the production answers each request as scoped.” Counsel sign-off is not delegable.
- 10Signed · ready to serve
The production, the log and the certification
Production agent · Lena Hartmann, records custodianThe production agent fixes the Bates numbers by request, from R1 contracts at DEL-000001 to R8, the scorecard method, produced Attorneys' Eyes Only. It builds the production volume, a DAT and OPT load file for 1,377 documents, natives with slip sheets, the 23-entry privilege log, the cover letter and the FRE 902(11) certification for Lena Hartmann to sign. It is served by secure link with a disclosure record. The hold stays on, because the litigation is still running.
The production agent never serves without the named approver's signature.