Document productions can be painful. Time is rarely on your side, there’s a very low tolerance for error, and surprises can pop up out of nowhere causing all kinds of headaches. Read a summary of production tips from Erika Namnath, the Associate Director of Technical Services within the eDiscovery Group at H5.

1. Document Productions:
Gain Without Pain
Erika Namnath, H5
You need it. We find it.

2. Managing Document Productions:
What can YOU do to help ensure your
productions will run without a hitch?

3.
Here are 4 tips that may help:

4. Tip #1: Know the ESI protocol like you
know your own name.
The MOST important rule of all.
• Following a sensible ESI protocol during
collection and processing can help you avoid
major hassles.
• Decide what to collect and HOW, as well as
processing options.
• Stick to your protocol!

5. Tip #1: Know the ESI protocol like you
know your own name (cont.)
Questions to Consider:
• Will this be a native or standard tiff production?
• Which metadata fields are to be produced? Do any
require custom handling?
• How do redactions and fully withheld documents
affect the metadata?
• What are the requirements for exception handling?

6. Tip #2: Use Targeted Workflows and
Focused Reviewer Configurations
• Set up multiple levels of review, not just first
pass and privilege.
• Keep coding panels simple – too many
options are distracting.
• Make it as easy as possible for reviewers to
get to what they need to review.
• Keep completed/in progress sets out of the
available queue.

7. • Save time by creating dynamic saved
searches to feed various work streams
and keep tabs on what is ready to be
produced.
• Start imaging well in advance of
production.
• Use dynamic searches to trap unworthy
documents before they can be sent out
the door.
Tip #3: Take Advantage of Dynamic
Searches and Automation
Take the guesswork out of the equation.

8. 1. Use an automated batching schedule to keep
reviewers busy.
2. Send all document families with no coding to first
pass.
3. Send documents with responsive coding and
privilege indicator to more detailed privilege review
for later creation of the privilege log.
4. Target coding conflicts, e.g. inconsistent coding
within families, dupe groups, or threads, to be
excluded from production and sent for further
review.
Tip #3: Take Advantage of Dynamic
Searches and Automation (cont.)
How to Create A Search for Every Review Stream

9. • Take full advantage of powerful Analytics when
you can.
• At a minimum, apply email threading and
near-dupe identification.
• Group threads and similar documents to
increase accuracy and speed.
• Use Analytics to Enhance the Ability to Target
Coding Conflicts and Feed Higher Level Review
Streams.
Tip #4: Use Analytics

10. The Bottom Line:
• Pay attention to the protocol early on.
• Spend time at the beginning formulating your
plan and stick to it.
• Be flexible if things change.
• Leverage the tools you have at your disposal.
Your ESI Protocol is your best friend.

11. Erika Namnath is the Associate Director of
Technical Services within the eDiscovery Group at
H5. She focuses on litigation support services
including media management, processing,
imaging, and production.
Erika is writing a series of articles about eDiscovery
processing, hosting and production, featured on
H5’s Blog, True North.