Production

Stage 8 of the Electronic Discovery Reference Model

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Detailed Analysis

Production is the delivery of documents and data to the opposing parties in a format that has been agreed upon or mandated by the court. This stage ensures that the discovery obligations of the organization are fulfilled.

Documents are typically produced in one of three formats: Native (original file format), Image (TIFF or PDF), or Near Native (extracted text and metadata). Static images are often preferred because they allow for Bates stamping, where unique identifiers are applied to every page of the production, and ensure that redactions are permanently applied. The production must be accompanied by a load file that allows the receiving party to import the data into their own review software.

Standard components of a production: