
This specification governs the assembly and delivery of the production set identified above. It is the working document between the producing party, the review vendor, and the receiving party. Every field below must be filled in and every check must pass before the set ships. The set that leaves your door is the set opposing counsel gets to argue about. Get it right.
| Case Caption | |
| Court & Case Number | |
| Producing Party | |
| Receiving Party | |
| Producing Party Counsel | |
| Applicable Protective Order | |
| Applicable ESI Protocol |
Check the applicable format(s) for this production:
| Field | Count | Definition |
|---|---|---|
| Total documents to produce | Sum of coded responsive minus privileged withhold, plus attachments to responsive parents, minus dedup masters where original custodian preserved. | |
| Full-produce (no redactions) | Responsive, not privileged, no confidentiality-driven redactions. | |
| Redacted-produce | Responsive; contains material subject to redaction. Redactions applied per §6. | |
| Native-only produce | Spreadsheets, media, complex CAD — items where imaging degrades content. | |
| Withheld (privileged / work product) | Logged in DLC-M07-001 privilege log accompanying this production. | |
| Withheld attachments to produced parents | Slip-sheeted in production; family relationship preserved via GroupID. |
| File Type | Treatment | Notes |
|---|---|---|
| Excel (.xlsx, .xls) | Native + slipsheet | Placeholder image with "Produced in Native Format" endorsement and Bates on slipsheet. |
| PowerPoint (.pptx, .ppt) | Image + native | Image includes notes pages if not redacted. Native available on request or per protocol. |
| CSV / TSV / structured data | Native + slipsheet | Same as Excel. |
| Audio / video | Native + slipsheet | Transcript, if available, delivered as extracted text. |
| Email (.msg, .eml) | Image + text + native | Attachments imaged; family preserved. |
| Image + text + native | Original PDF preserved. | |
| Word (.docx, .doc) | Image + text | Native provided only on request per stipulation. |
| Bates Prefix | |
| Starting Bates | |
| Bates Format | PREFIX + 6+ zero-padded digits. Sequential across production set. No skips. |
| Endorsement Position | Bottom-right, minimum 0.5" margin. Never overlaps content. |
| Confidentiality Legend | |
| Confidentiality Position | Bottom-center or per protective order. |
| Redaction Legend | Black box with "REDACTED" or "REDACTED — [reason]" per protocol. |
| Slipsheet Text | "Document produced in native format" or "Document withheld for privilege — see privilege log entry [Bates]" |
Redactions may be applied for the following reasons only:
Every redaction is logged with (a) the Bates of the redacted document, (b) the specific reason code, (c) the redacting reviewer, and (d) the reviewing attorney who signed off. See DLC-M06-002 Redaction QC Checklist.
Unless otherwise stipulated, the following metadata fields are produced with every document. Fields not listed are not produced.
| Field | Notes |
|---|---|
| BeginBates | Per §5. |
| EndBates | Per §5. |
| BeginAttach / EndAttach | Family preservation. |
| Custodian | All-custodians list if dedup'd. |
| DateSent / DateReceived / DateCreated / DateModified | ISO 8601 UTC. |
| From / To / Cc / Bcc | Emails only. |
| Subject | Verbatim. |
| FileName / FileType / FileSize | Original values. |
| MD5Hash | De-dup verification. |
| Confidentiality | Per §5 legend applied. |
| Redaction | Y/N flag with reason code. |
| NativeFilePath / TextPath / OCRPath | Relative to production root. |
Metadata itself may be redacted only for the reasons listed in §6. If metadata is redacted:
| Delivery Method | |
| Encryption Standard | AES-256 minimum. Password delivered out-of-band. |
| Manifest & Cover Letter | PDF manifest with production summary, Bates range, format description, and password recovery instructions. |
| Physical Media (if applicable) |
The producing party confirms that the above production has been assembled per this specification and the applicable protective order.