Production Is Not Just Printing to PDF
Legal productions often require images, text, metadata, native files, load files, endorsements, confidentiality designations, redactions, and family relationships. If those pieces are inconsistent, opposing counsel may receive a production that cannot be loaded, searched, cited, or tied back to the source set.
PowellPath prepares productions so attorneys can exchange records with a clear understanding of what was produced, what format was used, what metadata was included, and what exceptions remain.
The Protocol Controls the Mechanics
The governing ESI protocol, court order, party agreement, or discovery request may specify image format, native-file treatment, metadata fields, text files, load-file format, Bates numbering, redaction treatment, and confidentiality labels. Production preparation should start by translating those requirements into a concrete build checklist.
If the protocol is vague, counsel should decide the assumptions before production begins. Ambiguity about native spreadsheets, databases, audio/video, redacted files, parent-child relationships, or privilege placeholders can create avoidable disputes.
Quality Control Should Happen Before Delivery
Production QC should confirm that Bates ranges are continuous, confidentiality labels appear correctly, redactions are burned in where required, native files match their placeholders, metadata fields align with the load file, text files are present, and document families remain intact. It should also identify password-protected files, failed conversions, missing text, unsupported file types, and records withheld for privilege.
A production that fails technically can distract from the merits. A production that fails privilege or confidentiality review can cause far greater problems. QC is therefore part of legal risk management, not clerical polish.
Production Components
- Bates numbers, volume names, confidentiality legends, and redaction labels.
- TIFF, PDF, native, text, and mixed-format production sets.
- DAT, OPT, LFP, or other load files required by the review platform or protocol.
- Metadata fields, extracted text, OCR text, and native-file links.
- Privilege placeholders, family handling, redaction logs, and exception reports.
- Production QC summaries and delivery manifests.
What Counsel Receives
Deliverables may include a production-ready volume, load files, native-file folders, text files, metadata exports, privilege placeholders, exception reports, QC notes, and a production manifest. The work is designed to make the production usable to the recipient and defensible for the producing party.