Paralegal how-to
How to Prepare a Document Production
Organized productions save time and reduce risk of producing privileged material.
Quick answer
Organized productions save time and reduce risk of producing privileged material. In short: collect; remove; have, then complete the remaining steps below.
Step by step
Collect documents from the client according to the discovery request.
Remove duplicates and organize by request or custodian.
Have attorneys review for relevance and privilege.
Create a privilege log for withheld documents.
Apply Bates numbers and confidentiality labels as required.
Prepare the production letter and index.
Keep an exact copy of everything produced.
Safety reminders for paralegals
- Protect client confidentiality and privileged information
- Avoid giving legal advice: refer questions to attorneys
- Use secure systems for sensitive files
- Double-check deadlines to protect clients
Key terms
Pleading · Complaint · Motion · Discovery · Interrogatories · Deposition: see the full paralegal glossary.