Draft a Bates-stamp reconciliation protocol for the Response Production Checklist to resolve gaps and overlaps between party-provided and third-party subpoena productions

Production Scope Definition * Select production reconciliation scope Complete party discovery with overlapping third-party subpoenas Time-bounded document sets with cross-production overlaps Privilege log gaps between party and third-party productions Document families with inconsistent Bates numbering across sources Rolling productions requiring continuous reconciliation Redaction/release discrepancies between sources Privilege waiver impact across production sources ESI protocol compliance across multiple productions Rolling privilege review coordination Foreign language document reconciliation

Bates Range Uploads *

Production Source Details *

Reconciliation Criteria * Select reconciliation method Bates continuity analysis (identifying missing sequences) Custodian overlap detection (documents from same custodian across sources) Date range gap analysis between productions Email threading reconciliation across sources Family grouping completeness check Privilege assertion consistency Redaction version control alignment Metadata field standardization Load file format consistency check Native file availability verification

Stakes and Risk Level * Choose stakes level Bet-the-company litigation (0% error tolerance) High-stakes commercial dispute (FRCP Rule 26(g) expert review) Standard business litigation (standard ESI protocol) Regulatory investigation (privilege protection critical) Class action certification stage (statistical sampling) International arbitration (cross-border evidence rules) Government enforcement action (criminal referral risk) SEC disclosure review (materiality threshold) Patent litigation (claim construction documents) M&A due diligence (deal criticality)

Court/Jurisdiction Rules *

Production Timeline * Choose urgency level Emergency (same day resolution for court deadline) Urgent (48-72 hours for deposition prep) Standard (1-2 weeks for discovery cutoff) Rolling production (continuous weekly updates) Staged review (monthly privilege log updates) Pre-trial preparation (30-60 days before trial) Settlement preparation (pre-mediation exchange) Appeal record compilation (appellate deadline) Mock trial preparation (next quarter) Regulatory response (investigation timeline)

Privilege Waiver Concerns * Choose key privilege issues Subject matter waiver risk (privileged documents disclosed) Common interest materials (shared with third parties) Work product disclosure scope (litigation/strategy documents) Joint defense privilege (defense coordination) Attorney-client privilege logs (privilege claim errors) Cherry-picking disclosure (selective production) Selective waiver (government cooperation) Inadvertent disclosure protocol (clawback agreements) Third-party privilege claims (subpoena responses) International privilege concepts (cross-border issues)

Output Format Requirements * Choose output specifications Comprehensive production gap analysis report (PDF with exhibits) Interactive spreadsheet with pivot analysis (Excel with formulas) Privilege log coordination matrix (concordance format) Load file correction specifications (DAT/Text format) Court submission ready memo (legal brief format) Rolling update protocol (procedure document) Deposition preparation checklists (numbered lists) Trial exhibit foundation matrix (linked PDFs) Settlement negotiation summary (executive brief) Regulatory compliance report (formal documentation)

Additional Review Notes