I am sure you have heard of the expression, “Do unto others as you would have them do unto you”. Well, I believe that expression should apply to litigation support professionals. In many of the cases we work on, we are exchanging production data with opposing counsel or we are sharing production data with co-counsel. One of the most frustrating things for me is when I receive production data that is poorly organized. When this happens, I always vent out loud and I say something like “this data was prepared by a fellow litigation support professional — how could they be so inconsiderate to a colleague?” On the flip side, when I am preparing a production myself to send to someone else, I take into consideration that a fellow litigation support professional is going to receive it and I try to make sure that I provide the data in a format that is organized and easy to load.
Production data that is shared or produced on a rolling basis should be consistent across all deliveries. Below are some of the criteria that should be taken into consideration.
- The volume names should be named consistently and numbered consecutively.
- The header row in the load files should contain the same fields in the same order.
- The bates numbering should be named consistently and numbered consecutively.
- The image files should be named to match the bates number. If they are generically numbered beginning with 0000001, 00000002, then the load files should cross-reference the bates number (image key) with the generically named image files.
- The text files should be named to match the bates number.
- The native files should be named to match the bates number.
- The load files should either match your preferences as previously discussed or if there hasn't been a discussion, the load files should be formatted in a such a way that they are easy to convert from one format to another.
- There should be a load file for the database records as well as a load file for the image links.
- The file path to the native files should be provided in the database records load file.
- The label on the CD/DVD should reference the case name, the date, the volume name, the bates range, the document count and the page count.
Even if a different member of the litigation support team prepares each deliverable, the consistency should still be there because the team should have a workflow in place that allows each team member to know exactly how the previous deliverable was organized.
When preparing a deliverable, please ask yourself how you would prefer to receive the data and be considerate to your colleague that will be in receipt of your deliverable.