Document review is a necessary, but often labor-intensive and time-consuming, part of litigation support. Preparing an effective guidance document can help avoid costly errors and frustrating missteps by guiding the ediscovery team to evaluate critical information more efficiently. Ensuring that your guidance document includes the following elements can improve the effectiveness of the document review process:
- Overview of the legal matter. Provide enough information before beginning the process so the litigation support team understands the legal issues in your case and how the document review process fits into the overall case strategy.
- Relevant background information. It can also be helpful for the ediscovery team to have access to the subpoena, complaint, or other document requests, so they can see the context for the document requests they are responding to.
- Responsiveness and issue coding specifications. Provide an overview of the responsiveness categories and the document coding options you want reviewers to use for consistency and cohesiveness during the review process. You should also include why those issue codes are relevant to the case. This can reduce or eliminate instances of inconsistent document coding and minimize the changes needed during the quality control process. .
- Privileged documents. Provide information to help the litigation support team understand how to identify privileged information. This may include the names of any members of the legal department, and the names of outside law firms that have provided counsel to the parties and any agents working on their behalf. This can help ensure privilege is asserted accurately and consistently.
- Expectations. Finally, it is critical that anyone handling litigation support for your law firm or corporate legal department understands your expectations in terms of deliverables and time frame. Spelling these out upfront in a guidance document can ensure there are no miscommunications later in the process and ensure that document discovery is completed effectively and on time.
Baer Reed provides a full range of LPO services to law firms and corporate legal departments around the world, including litigation support services. To learn more, call us at 888-433-1990, or contact us online today.









Mr. Reyes graduated with honors from the Ateneo de Manila University, where he received the Procter and Gamble Student Excellence Award. He obtained his Juris Doctor degree from the Ateneo de Manila School of Law. During law school, Mr. Reyes was part of the Philippine delegation to the Willem C. Vis International Commercial Arbitration Moot held in Vienna, Austria. He was also a member of the Ateneo Society of International Law and the St. Thomas More Debate Society. He completed his internship at the Public Attorney’s Office. He wrote a thesis entitled: “To Kill A White Elephant: An Analysis of the Fiduciary Exception to the Corporate Attorney-Client Privilege”. Mr. Reyes is admitted to practice law in the Philippines and the State of New York.
Ms. Lardizabal-Manzano is a graduate of San Sebastian College-Recoletos, where she earned her B.A. in Political Science. In 2003, she received her law degree from Lyceum of the Philippines and was admitted to practice law in 2004.
Matthew Hersh earned a B.A. in Political Science from Columbia University in 1990 and graduated cum laude from Georgetown University Law Center in 1999. He also holds a master’s degree in international relations from the Georgetown University School of Foreign Service.
Cap. Avi Levak (Res. IDF) graduated from from Israel’s prestigious Ben-Gurion University of the Negev with a Bachelor of Science in Computer Science and Mathematics. He is also a Leadership and Communication coach trained in TuT coaching by Alon gal in Israel. Avi specializes in high-level, in-depth analysis of business and client needs, within systems and software strategy and architecture.
Ms. Tyler graduated cum laude from Georgetown University and received her law degree, cum laude, from Georgetown University Law Center. During law school, she interned at the United Nations Economic Commission for Europe. She also worked on The Tax Lawyer journal and was a member of the award-winning Barristers’ Council Mock Trial Team. Ms. Tyler is admitted to practice law in the State of California and the District of Columbia.
Ms. Cruz-Anonuevo graduated cum laude and top nine in her batch from Miriam College with a degree of Bachelor of Arts in InternationalStudies. She obtained her Juris Doctor degree from Ateneo de Manila University School of Law in Rockwell. During law school, she interned in Rivera, Santos, Maranan & Associates. She was also part of Ateneo’s Labor Law Bar Operations. She wrote her thesis on, “Stealing Privacy: Limitations on Media’s Photographic Invasion.,” Ms. Cruz-Anonuevo is admitted to practice law in the Philippines.
Ms. Aquino-Batallones obtained a Bachelor of Arts degree in Development Studies (with Minors in Global Politics and Hispanic Studies) from the Ateneo de Manila University. In 2011, she received her Juris Doctor degree from Ateneo de Manila University School of Law. During law school, she interned at Romulo Mabanta Buenaventura Sayoc & de los Angeles then became an intern of Ateneo Legal Services Center’s Clinical Legal Education Program.
Mr. De Guzman graduated from San Beda College with a degree of Bachelor of Arts Major in Economics and received his law degree from San Beda College of Law. He is multilingual and is fluent in three languages: Chinese, Filipino, and English. He was admitted to the Philippine Bar in 2003.