Identifying documents for collection in response to a discovery request is no longer as simple as just going to a file cabinet. Documents can still be in paper form, of course. However, they are just as likely, if not more likely, to be found in network system drives, email and electronic calendar records, removable storage media, on laptop or desktop computers, tablets, and other handheld devices.
When a discovery request is received, it should be reviewed so that the scope of the document collection can be identified. The document request itself should include, with reasonable specificity, a description of each item or category of item for which documents are being requested.
Attorneys and law firms handling a discovery response should familiarize themselves with their client’s data storage systems and document retention policies before beginning to identify and collect documents to meet the request, since this will impact the document collection procedures. Reasonable efforts should also be made to identify all personnel who may have relevant documents in their possession, and to notify such personnel of the need to preserve those records during the course of litigation.
Using a centralized document management solution, where every document is stored in a single document repository, can help firms handle what are often voluminous requests to produce documents and records. These document review platforms generally offer web-based data hosting such that team members working in many different locations will have secure access to the platform.
The documents for collection should then be reviewed for responsive documents and privileged communications. It is crucial to ensure that documents provided in response to discovery requests do not include attorney-client communications or confidential information. If the documents are in multiple languages, it may be necessary to engage a foreign language review team to accurately review the documents before production.
Baer Reed assists law firms and in-house legal departments with document and privilege review, as well as foreign language document review. In addition, Baer Reed also supports teams doing paper document collection in southeast Asia. To learn more, contact us at (888) 433-1990 or visit us online.
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.