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Once a document collection review is completed, documents typically need to be produced to opposing parties, this is known as a production. Database administrators prepare the electronic production using Concordance Desktop, based on queries or tagged sets of documents that are identified for production during the review phase.

Concordance Desktop provides two production options:

•Standard production - produces a set of TIF or PDF files, .opt and a .dat load file.

•Native production - copies original native files out to a production destination directory and the files can be renamed with the production numbers. No redactions or other production type operations happen, simply a copy and rename. for more information about Native File production, see Running a native file production.

Managing Rolling Productions

Due to the ever-increasing size of electronic productions, litigation support staff are often faced with the task of handling and tracking large volumes of data that are incoming and outgoing during the life cycle of an e-discovery project. As a best practice, we recommend establishing an organized tracking method to ensure that all data is properly handled and nothing is missed.

Examples of Data Types Handled During E-Discovery

Here are some examples of data that can be handled during a large e-discovery:

•Data coming from clients that needs to be processed. This could include paper documents, electronic files, e-mail files, images, metadata load files, transcripts, graphics, and audio/video files.

•Data being produced from opposing parties to be loaded into a review tool, such as Concordance Desktop, for review by attorneys, paralegals, experts or investigators.

•Data going out to vendors for processing, scanning, coding, or printing.

•Data to be processed in-house using an e-discovery processing software, such as CloudNine™ LAW.

•Data such as exhibits, graphics, and presentations being prepared for trial to be loaded into trial presentation software.

•Transcripts and audio/video files from court reporters to be loaded into a transcript database for review and analysis.

•Data being copied or produced to other parties for review such as co-counsel and experts.

•Data being produced to opposing parties.

•Data that is to be archived from the network to disk or hard drive storage.

•Data that requires special handling, such as compliance with destruction or preservation orders.

Tracking Data

There are many ways that data can be tracked using database software tools specifically designed to help facilitate data tracking for e-discovery, such as Concordance Desktop, Microsoft Access, or Microsoft Excel.

CDs, DVDs, and external hard drives are typically labeled using some sort of uniform numbering system so that it is possible to track all incoming and outgoing volumes. Production volumes are also usually numbered in a series for record-keeping purposes. It is also important to keep track of production Bates number series to avoid accidental production of documents with overlapping Bates numbers.

Archiving Data

Establishing a uniform system for archiving data that must be preserved, but is no longer being actively used is also important. Maintaining a uniform archival tracking system makes it easier to locate data in the event that it must be recovered from storage and uploaded to the network at a later date.

We also recommend that you become familiar with your organization's backup, retrieval, and data retention policies so that you are prepared in the event that you need to recover data on short notice.

Production Elements

Numbering Documents

As part of the production process, a new set of files are generated for documents that need to be produced. A Bates number series is then applied to all pages of all documents included in the production, with the option of burning or fusing the numbers to the image during the process. This number series usually differs from that of your internal collection. You can then track what has actually been produced and your Bates number series for the production is sequential with no gaps in the numbering.

Burning Annotations

Redactions or other redlines can be burned to the images during production so that they cannot be altered. Confidentiality headers or footers can also be burned to the images during production. Production numbers are usually cross-referenced to those in the original review collection.

If the Concordance Desktop administrator included fields for production numbers in your database, these numbers are then written to the production number fields during the production process. Later when you look at your internal document collection, you are able to see the production number for any documents that were produced.

For multiple or rolling productions, tags or sequentially numbered production fields are tracked for which production series a document was produced under. For example, fields named BEGPRODNO1/ENDPRODNO1, BEGPRODNO2, ENDPRODNO2, etc.

Production Output

The output generated by a production run in Concordance Desktop is a set of TIF images or PDF files and a load file. Both the production set and the load file are typically burned onto CDs or DVDs (or for very large collections, an external hard drive). Output volumes, such as CDs or DVDs, are labeled to track the production series.

Native Files

For native productions, the set of documents to be produced is typically converted to image or PDF files prior to production. Organizations need to adhere to proper forensic procedures for handling native files.

Generating Load Files and Images

The output from a production is a set of images and an image load file. The output generated depends on production requirements agreed upon with opposing counsel. A best practice is to know in advance what the recipient needs for output format.

Production load files enable recipients to import images into their own viewer software. Images and load files are generated for either single or multi-page, TIFF or PDF format.

Administrators can also export specific field data to a delimited file, .dat, .csv, etc., to accompany the produced OPT and images.  If new production numbers are created as part of the production, be sure to write the beginning and ending numbers back to fields in the database so they are available for export and also cross reference with any original document numbers.

Concordance Desktop export processes work well with most of the review tools on the market, or Concordance Desktop data can be converted to something that will work.

Productions and Concatenated Databases

•When running productions on a set of concatenated databases for native files, all the databases in concatenated set must have identical database structures and have matching Media (Image) key field names across the concatenated set.

•Native file productions will only be performed on the primary database when differing database structures (any one of the field names is different between the primary and secondary databases or any additional fields exist in any one of the databases) are included in a concatenated set.

•Productions for differing database structures should be run separately for each database.

•Productions should be run on the machine without any other applications running.