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Discovery: how it works

Review incoming evidence, responses and productions, then follow linked opposing answers into witness preparation. Keep attribution, objections, transcript lineage, privilege and outgoing-set review distinct.

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Availability

Limited availabilityDiscovery review and preparation can be scoped for a pilot. Confirm production-export support and attorney review requirements in writing before using it.
Supported work
Turn source-linked gaps into focused requests, review what comes back and carry recorded answers into witness preparation.
Start with
The registered witness’s cross plan can reuse linked opposing discovery answers and recorded impeachment conflicts. The response’s wording, objections and attribution cautions remain attached.
Key limit
Discovery review and preparation can be scoped for a pilot. Confirm production-export support and attorney review requirements in writing before using it. Coverage counts the review work that was recorded. A missing attachment is a question to raise, not proof that anything was withheld.

Some capabilities have their own availability or configuration requirements, shown below.

Before you start

  • The registered witness’s cross plan can reuse linked opposing discovery answers and recorded impeachment conflicts. The response’s wording, objections and attribution cautions remain attached.
  • A reviewed requirement and its supporting or adverse facts help scope discovery. An explicit evidence-matrix run proposes gaps only from its bounded retrieved excerpts; the ordinary production review and portal request remain separate workflows.
  • For North Harbor, supply agreement §9.2 and the conflicting Garcia and Smith testimony frame the notice question. The returned email and attached report record sending; receipt, reading and the absent review-meeting notes still inform the proposed supplier request.
  • Where enabled, a source-quoted reading of the other side’s numbered responses distinguishes answers, objections, conditional answers, promised documents and missing responses. Proposed deficiencies retain the words they rest on, and a numbering disagreement is shown for counsel to resolve.
  • Your own response workspace keeps numbered requests, answers and objections together. Compilation is ready only when every item is final; it does not confer document review, signature, production or service clearance.
  • Discovery review and preparation can be scoped for a pilot. Confirm production-export support and attorney review requirements in writing before using it.
  • Productions as load files or as the documents themselves. BRON reads and writes Concordance DAT, Opticon OPT and EDRM XML.
  • Custodians and litigation holds recorded on the matter. Coverage counts only the review work that was recorded.
  • For the 14-day objection deadline, the other side's Rule 26(a)(3) designations recorded on the matter.

How it works

Read conflicting accounts beside their sources and the requirement counsel has reviewed. Identify what evidence could resolve the question, prepare a focused request, and inspect the answers and objections. Counsel reviews privilege and the exact outgoing set before anything is produced.

What evidence could resolve this issue, who may hold it, and what should the proposed request ask for?

From proof gap to evidence question

  • Read the requirement beside the conflicting accounts

    The notice question starts with supply agreement §9.2: written notice of a defect within 30 days of delivery. Garcia Dep. 118:4 says “Before May 4.”; Smith Dep. 44:12 says “Only after May 4.”. Counsel decides which facts matter to that requirement before choosing what to request.

  • Ask what would distinguish the two accounts

    The May 2 email records a sent event. It leaves receipt, reading and the review meeting unresolved. Compare supporting and adverse facts in the fact-to-element matrix, then choose the document, testimony or custodian question that could bear on that specific uncertainty.

  • Read what has already come back

    The client returned defect-email.eml and its defect-report.pdf attachment. The review-meeting notes were not found in the named sources. Read the email beside its attachment before treating the return as an answer to when Smith received or read it.

  • Choose the request and the right source

    Request for production No. 1 asks for Smith's copy of the May 2 email, its delivery records, and the review-meeting notes. An explicit evidence-matrix run can propose gaps from retrieved excerpts; counsel can prepare a document request, interrogatory or deposition topic. A recorded fact or element can also inform a scoped device question on accepted sources. These paths have separate review, with no automatic service or automatic element-gap-to-portal request.

  • Read the return before changing the theory

    Keep the original email beside its attachment and production reference. Record what arrived, what was not found in the named sources and what counsel still needs. After review, use the source-linked facts and chronology to revisit the notice analysis, the next request or the adversarial position.

From discovery to examination

  • Put the opposing answer into the cross plan

    Linked opposing discovery responses enter witness preparation with their wording, objections and attribution cautions. Counsel decides whether that witness can speak for the response. An answer linked to the matter is not automatically that person’s sworn admission. North Harbor’s returned email is not an opposing discovery answer.

  • Keep transcript versions and trial anchors distinct

    Rough, certified and corrected testimony have separate lineage. Errata and corrected versions can affect designations and proposed facts; counsel reviews and re-anchors affected trial work. A correction does not silently rewrite the earlier transcript or its recorded anchors.

Responses to the numbered requests

  • Keep the answer, objection and outstanding promise together

    Where enabled, the written-response reader proposes which numbered requests were answered, objected to, answered subject to objections or promised documents. Each reading must stand in the paper’s own quoted words. Numbering disagreements and unknown verification remain visible; counsel reviews proposed deficiencies before preparing a meet-and-confer.

  • A compiled response still needs its own review

    Your response workspace keeps each request beside its answer and objections. Compilation is ready only when every item is final. Client factual input stays within the selected recipient’s permissions, with verification where required; finalizing items does not clear classification, signature, production or service.

A production arrives

  • A missing attachment and its reference

    Available

    An email, its attachments and the load-file rows sit together as a family. When the email refers to an attachment the production does not contain, the gap shows with the reference that points to it.

  • Check keyword matches against the email

    A keyword search finds emails that seem to mention an attachment. BRON then reads the email and confirms or rejects the match with a quotation. A match it could not check stays marked unconfirmed.

  • Read Bates gaps in context

    Available

    BRON finds Bates gaps and incomplete families from the production's own numbers. Where the load file gives one number per document, a gap is phrased as a question, because the pages inside a document look like missing numbers.

  • Findings quote their source

    Each finding quotes the line it rests on. Running the scan again updates open findings and does not reopen one an attorney dismissed.

  • Read and write production load files

    Available

    BRON reads and writes Concordance DAT, Opticon OPT and EDRM XML load files for incoming and outgoing productions.

Raising it with the other side

  • Draft the meet-and-confer letter

    Available

    A deficiency becomes a meet-and-confer letter built from a fixed catalog and the attorney's own entries. The cure-by date is left as a placeholder for the attorney, and the exchange builds the chronology for a Rule 37(a)(1) certification.

  • The objection period starts as a proposal

    Recording the other side's Rule 26(a)(3) designations proposes the 14-day objection deadline for an attorney to confirm. Nothing goes on the calendar until then.

Review

  • Review order learns from your coding

    Available

    BRON ranks the uncoded documents by what an attorney has already coded, so review starts with the documents most likely to be responsive. It learns only from decisions an attorney recorded.

Before your production leaves

  • Classification keeps the more protective reading

    Available

    When a model and a rule-based scan classify a document differently, BRON keeps the more protective classification.

  • Inspect the exact proposed production

    Available

    Production preparation checks recorded classification and review status. Counsel must inspect the exact proposed set before release. Privilege checks and attorney confirmation remain required, and production acts are recorded in a log that is not edited.

  • Privilege problems are separate findings

    Available

    A privileged document found in a production and a withheld document with no privilege-log entry are reported as two different findings.

  • Hold notices wait for the attorney

    BRON drafts a litigation-hold notice for each custodian, with a link to acknowledge it. Issuing the notices needs the attorney's approval.

What it reads from

  • Matter intelligence
  • Each production and its load file
  • Custodians and litigation holds
  • The privilege log
  • The agreed production format

Who can do what

  • Counsel checks whether the witness can speak for an opposing response. Matter linkage does not make another party’s answer the witness’s own sworn admission.
  • Counsel chooses materiality, scope and recipient. For the North Harbor question, distinguish an email being sent from evidence of receipt or reading, and review returned originals before relying on them in strategy or trial preparation.
  • Responsiveness calls are the attorney's. The review order learns only from decisions an attorney recorded.
  • Producing documents and issuing hold notices each need the attorney's approval. An attorney confirms a proposed deadline before it is calendared.
  • The attorney sets the cure-by date in a meet-and-confer letter. BRON leaves a placeholder.
  • Where a model and a rule-based scan classify a document differently, the more protective classification is kept.
  • Client factual input is scoped to an eligible recipient with document access. Counsel reviews the response and required verification; client input does not authorize production or service, and a verification request must clear the document’s client-disclosure checks.

What it produces

  • The meet and confer, and a motion to compel
  • Drafting and the citation check
  • Deadlines
  • Trial exhibits and designations
  • Valuation

Limits

  • A gap is what the production does not contain between its own first and last numbers. A missing attachment is a question to raise, not proof that anything was withheld.
  • Coverage counts the review work that was recorded. It says nothing about material nobody recorded.
  • Discovery review and preparation can be scoped for a pilot. Confirm production-export support and attorney review requirements in writing before using it.

What BRON will not do

  • Scan a production it cannot read in full.

    A production over 200,000 documents is not scanned for gaps at all. A partial scan could report a clean set when part of it was simply unread.

  • Accuse the other side on a keyword match alone.

    A keyword match stays marked unconfirmed until BRON finds the quotation in the document, and a letter built from it says so.

  • Fill in a cure-by date.

    The attorney sets that date. The meet-and-confer letter carries a placeholder until they do.

  • Produce a document it could not look up.

    A failed privilege lookup blocks production preparation. Resolve the missing status and review the proposed set with counsel before release.

  • Calendar an objection deadline from a proposal.

    BRON proposes the deadline and an attorney confirms it. Only the confirmation puts it on the calendar.

When something goes wrong

  • Transcript versions, errata and trial anchors remain distinct. Corrected testimony can require reviewed designation or fact updates and re-anchoring; it does not silently replace the earlier recorded version.
  • No support found by a retrieval run is not a conclusion that evidence does not exist. A draft request, deposition topic or meet-and-confer has not been served or noticed.
  • A production over 200,000 documents is not scanned for gaps. A partial scan could report a clean set.
  • A keyword match that BRON could not confirm against the document stays marked unconfirmed, and a letter built from it says so.
  • Where the load file gives one number per document, a numbering gap is phrased as a question.
  • Production preparation checks recorded classification and review status and refuses a failed privilege lookup. Counsel must inspect the exact proposed set before release.
  • Running the scan again updates open findings and does not reopen one an attorney dismissed.
  • A written-response reading with no grounded quotation cannot supply a known answer or verification. Provider failures and unavailable readings remain disclosed; the proposed meet-and-confer does not send itself.
  • An opposing party’s response carries instrument-specific limits: an interrogatory answer needs its verification checked, while a production response is counsel’s statement about documents. The North Harbor email return supplies neither a recorded opposing answer nor a registered-witness link.