Attorneys understand the importance of the labor-intensive process of document review in response to the opposing party’s request for production of documents. The review must be comprehensive so that all relevant, non-privileged, non-confidential documents that are responsive to the request are produced. If not, the court may impose sanctions for withholding documents.
Before the review can begin, the legal team that is conducting the review needs to be clearly cognizant of the underlying legal and factual issues in the case. The most important reviewing factor to begin with is a determination of what makes a document relevant. Some suggest the review is best done in stages.
Initial Document Review Screening
Each document is first evaluated for relevance and tagged with a code indicating its subject matter. It may be helpful to also code documents to certain key facts in the case or to a specific witness who is expected to testify.
Entering Codes into a Database
After the documents are coded, the codes are entered into a searchable database. This provides an efficient way for any document to be located at all stages of the legal process.
Second Evaluation
This is to determine whether documents must be produced or there is a basis for withholding them. Documents can be withheld if:
- They are not responsive to the request. The request for documents must be carefully compared with the documents themselves. Even if they are relevant to the general issues in the case, if they are not responsive to a specific request, they don’t need to be produced.
- Privileged documents. These are documents that are protected by the attorney-client privilege, reflect attorney work product, or confidential according to any relevant rules, orders, or privacy laws.
Confidential documents should be analyzed to see if they can be produced if certain information is redacted.
Many law firms and corporate in-house counsel are taking advantage of outsourcing the complex task of document review. Baer Reed is an offshore legal services provider that offers cost-effective and efficient comprehensive legal document review. Contact us today for more information on our document review services.









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.
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. 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.
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.
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.
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. 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.