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03 · Discovery

Read the production once. Know what it proves.

BRON reads the held record against the claims, custodians, privilege posture and outstanding requests, and keeps every finding attached to the page that produced it.

MATTER 25001DISCOVERY
What does the production prove, and where is the gap?
01 · PRODUCTION412 documents readgrounded
02 · FAMILY CHECK3 attachments referenced, 1 absentreview
03 · PRIVILEGE2 pages need an attorney callreview
04 · BATESGap phrased as a questionreview

Sources stay attached to every finding.

The question in the room

They produced 4,200 documents. What is missing, and can I prove it before the meet and confer?

How it works

The mechanism, not the promise.

  • Seven kinds of gap, and a ledger that remembers your answer

    Findings land as a closed set of kinds covering Bates holes, broken families, referenced attachments and documents that never arrived, privilege that should not have been produced, material withheld without an adequate log entry, and specification violations. A finding you resolved or dismissed is never reopened by a later scan.

  • A gap hunter with no model in it

    Shipped

    The passes are deterministic, because an accusation leveled at opposing counsel has to be machine-provable. Only documents carrying email indicators are scanned for attachment references, since attached hereto in a contract is legalese rather than a missing file.

    backend/src/lib/discovery/gapHunter.ts

  • A gap phrased as a question when it must be

    Shipped

    Where the load file discloses document-level numbers only, the gap is reported as a question rather than as an accusation of withholding.

    backend/src/lib/discovery/productionImport.ts

  • A standing produced-versus-privileged diff

    Shipped

    Two different alarms, never merged: privileged material that reached a production, and material withheld without an adequate log entry. Adequacy is a named defect list, because every content column is nullable and a blank row once satisfied a presence check while discharging nothing.

    backend/src/lib/discovery/privilegeLog.ts

  • Classification takes the more protective of two

    Shipped

    Where a model and a heuristic disagree, the more protective reading wins, and the basis stays visible for review.

    backend/src/lib/compliance/autoClassify.ts

  • A continuous-active-learning ranker

    Shipped

    Review order is learned from the calls already made, by a deterministic pass over embeddings the matter already holds.

    backend/src/lib/discovery/tarRanker.ts

  • Load files, read and written

    Shipped

    DAT and OPT in both directions, so a production arrives and leaves in the form the other side actually uses.

    backend/src/lib/discovery/loadFile.ts

  • The outbound set

    Shipped

    Specification, privilege log, redaction and meet-and-confer, kept on the same record as the inbound findings.

    backend/src/lib/discovery/meetConfer.ts

Refusals

What it will not do, and why.

Hunt a production it cannot read in full.
Past its document ceiling the hunt is declined outright. A partial production cannot be hunted honestly, and a short hunt would report a clean set rather than an unread one.
Accuse the other side of your own privilege hygiene.
The two outbound privilege kinds are excluded from the deficiency catalog by name. They are ours, not theirs.
Advise you to log your own filed brief.
That advice was shipped and then removed. The candidate set includes the firm's own filed motions, served responses and hold notice, so following it would put a public filing onto the log served on opposing counsel.
Call a page unread and a page unreadable the same thing.
An unread page is deferred with a continuation row naming where to resume. A page that will not be read is truncated. One is a queue, the other is a limit.

One record

Nothing here stands on its own.

What feeds it

  • The matter brain
  • Every production and load file
  • The privilege log

What it feeds

  • Drafting and the citation gate
  • Deadlines
  • Trial exhibits
  • Valuation

Limits

What this does not establish.

  • A gap is what the received set does not contain between its own first and last number. It is not proof of withholding.
  • A rate with no denominator is reported as unmeasurable, never as zero.

Check the work before you believe it.

Run a sample manifest in your own browser, or read where publication refuses for want of evidence.