Garcia to Smith · May 2, 2025, 9:14 AM
Discovery
Find the gap. Draft the follow-up.
Read each email beside its attachments, and see when one is missing. Draft the follow-up from the gap, then bring the proposed production to counsel for review.
Availability: Limited availability
Discovery review and preparation can be scoped for a pilot. Confirm production-export support and attorney review requirements in writing before using it.
BRONDiscoveryNorth Harbor · discovery
412Documents received
Read beside the emails that refer to them.
Read beside the emails that refer to them.
Attachment 01
ReceivedAttachment 02
ReceivedAttachment 03
Absent
ReceivedAttachment 02
ReceivedAttachment 03
Absent
Inspect the source record
01 · EMAIL RECEIVEDdefect-email.eml · Garcia to Smith · May 2, 2025, 9:14 AMIn the record
02 · ATTACHMENTdefect-report.pdf · Attachment to the emailIn the record
03 · REVIEW-MEETING NOTESNot found in the sources the request namedFor review
04 · STILL OPENWhen Smith received or read the emailFor review
About this example
In practice
What arrived, and what did not.
Read the family.
An email, its attachments and the load-file rows sit together. A missing attachment shows as a gap, with the reference that points to it.
BRON / Discovery01Received set / family review
Turn the gap
into a request.FileReceived setdefect-email.emlReceiveddefect-report.pdfReceived · attachmentReview-meeting notesReferenced, not receivedReferenced in testimony
Garcia Dep. 118:13–18: Recalls meeting notes. Did not bring them and does not have a copy.
Request for production No. 1 asks the supplier for them. A missing file is a question to raise, not proof that anything was withheld.
North Harbor · Notice of defect · Illustration · fictional matter Raise it with the other side.
Draft the request for production or the meet-and-confer letter from the gap. The attorney sets the cure-by date. The exchange becomes the chronology for a motion to compel.
BRON / Discovery02Recorded review decisions
What has been
reviewed so far.Supply agreement.pdfResponsiveDecision recorded · Alex Chen
defect-email.emlReview pendingWith Elena Rivera. Not yet reviewed.
Review-meeting notesOutside this review setNot in the sources the request named, so there is nothing to code.
Share of the set reviewed
Not measured yet.
Coverage counts the review work that was recorded.
North Harbor · Notice of defect · Illustration · fictional matter Review the proposed production.
Inspect the proposed set, classifications and review status with counsel. Privilege checks and attorney confirmation remain required before release.
BRON / Discovery03Outgoing production / counsel review
Held back until
privilege is reviewed.Documentdefect-report.pdfPrivilegeReview requiredClassificationMore protective reading keptProducing itNeeds the attorney’s confirmationProduction held for reviewIt cannot be produced until privilege is reviewed.
North Harbor · Notice of defect · Illustration · fictional matter
What this carries into the rest of the matter
- Gaps in a production, as follow-up requests and meet-and-confer letters.
- The meet-and-confer exchange, as the chronology for a motion to compel.
- Each production you serve, in a production log that is not edited.
One decision in practice
The email and its attachment, without the notes.
It came with the email and sits beside it.
Not in the sources the request named. That is a question to raise, not proof that anything was withheld.
?ATTACHMENT NOT LOCATED
Your next decision
Counsel decides what to ask for. Request for production No. 1 would ask the supplier for Smith's copy of the May 2 email, its delivery records, and the review-meeting notes.