Technical field guide
The sections below preserve the service-specific depth behind eDiscovery Production Services, edited for the current national practice and its documented engagement model. Methods are selected for the source, authorization, system state and assigned specialty. No single tool or artifact establishes a conclusion, and legal, regulatory or certification decisions remain with the responsible authority.
What This Solves
Production is where discovery disputes most often crystallize. A format that does not match the agreed production protocol, a Bates numbering error, a missing load file field, or an over-redacted document can generate objections, motion practice, or court-ordered re-production. None of those outcomes are acceptable when a matter is already under deadline pressure.
GDF treats production as its own quality-controlled workflow, separate from the review phase. Documents cleared for production go through a dedicated production preparation and verification process before delivery. The result is a production set that matches the agreed specification, includes required documentation, and is verified against the source data before it ships.
Supported Production Formats
Production can be prepared in common native, image, text and load-file formats. The format is agreed during production specification review, and GDF confirms that the receiving party's review platform can ingest the selected format before the production set is assembled.
- TIFF images with extracted text and standard load file (Concordance, Summation, EDRM XML)
- Native format production with metadata load file
- PDF with optical character recognition text and document-level metadata
- Hybrid productions: TIFF for most documents, native for select file types such as Excel spreadsheets and audio files
- Relativity load files (.dat and .opt format)
- Custom formats for regulatory productions to the SEC, DOJ, FTC, or state attorneys general
Privilege Log Support
A privilege log that does not satisfy the receiving party's specificity expectations delays the matter and can generate motion practice. When counsel requests a privilege log, the review workflow can build it alongside coding so entries and exceptions can be reconciled before production.
Standard privilege log fields include: document identifier (Bates number or control number), document date, document type, custodian, author, all recipients, privilege ground, and a factual description that identifies the nature of the communication without revealing the privileged content. Courts in several circuits have specific requirements for privilege log format and content. Counsel defines the required fields, categories and governing orders; the technical workflow applies that approved specification.
Where counsel approves categorical logging, the workflow can apply the defined categories, reconcile counts and prepare the supporting records counsel directs.
Redaction and Redaction Logs
Redactions applied during review are verified during production preparation. Redaction quality control should confirm placement, burned-in output where required, text-layer treatment and reconciliation to the redaction log.
The redaction log records: document identifier, Bates range for the redacted page or pages, redaction reason code, and the date the redaction was applied. For productions involving personal health information, personally identifiable information, or confidential business information, the redaction log provides the documentation that supports the producing party's position if the redactions are challenged. Pre-redaction versions should remain protected under the matter's access, retention and custody controls.
Rule 502(d) Clawback Support
Rule 502(d) of the Federal Rules of Evidence allows parties to obtain a court order specifying that disclosure of privileged material does not constitute a waiver, which enables faster pre-production privilege review and establishes a clear process for recovering inadvertently produced documents. When counsel supplies an applicable clawback protocol or order, the production workflow can track designated items, apply the required review step and preserve the information needed for counsel's notice process.
The clawback log records: document identifier, date identified as potentially privileged, date notice was sent to receiving party, receiving party confirmation of return or deletion, and any subsequent court proceedings related to the clawback. That documentation becomes part of the matter record and is available to support any privilege dispute that arises after production.