Litigation document productions involving electronically stored information frequently begin with a very lengthy set of specifications that determine what metadata elements need to be produced, what type of renditions of the electronic files should be included, and details of ancillary reports that must accompany the production load files. For an example, see .

Frequently, because of heavy workloads or large data volumes, the receiver of the data will not load the production as soon as it arrives. At an unexpected time, contemporary to the production delivery, additional data may be requested to facilitate successful loading or review of the produced data.

These delays in follow-up risk that the production processing information needed to supplement the delivery is no longer available or is not in a state that is conducive to active use. Production processing organizations tend to retain the final production load files as delivered, but they may not retain that information in active storage. In some cases, processing groups load the production information to a retrieval database. However, they frequently remove or archive inactive processing files. This can all be a bit of a shell game. See “The Production Edit Shell Game”.  For instances where the processing copy of the data can expedite delivery of production adjustments, an early check of the production delivery ensures that all of the required source information is available.

When time is limited, some checks can be performed without loading the data into the receiving database. See the following for items that can be checked using text editors, low end RDMS tools and spreadsheets in most cases.

Typical Production Receipt Checkpoints:

  1. Confirm that the correct starting Bates number was used.
  2. Compare the number of documents listed in the load file to the number of documents identified at the source used for the production.
  3. Compare the number of document/image records to the number of text and image cross reference records.
  4. Check for the listing of all required fields in the load file.
  5. Verify the population of all fields.
  6. Check for a correct starting Bates number.
  7. Confirm that endorsements of Bates numbers and designations, like Confidentiality, been applied to images properly.
  8. Check samples of any expected exceptions for tiffing. (Ie. Redacted, slip sheeted, password protected files, unsupported file types, foreign language documents, documents with no text, media files, privileged documents in responsive attachment families, etc.)
  9. Confirm custodian and duplicate custodian information.
  10. Confirm addition of any information that did not directly export from the document database, like “production entity”, calculated fields, designations assigned to the production set as a mass production entry.
  11. Confirm parent/attachment references within attachment families in the proper fields.
  12. Make sure that all required processing reports been provided with the document/image counts in the reports matching the production file and load file record counts.


Capital Novus provides a means to build checkpoints like these into QC templates in eZManage.




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