E-Discovery Status Report

E-Discovery Status Report

Produces an attorney-work-product status report tracking ESI from collection through review for U.S. commercial litigation.

Prerequisites

Gather before starting. Flag and caveat any gaps in the report.

1. Vendor collection logs — custodian names, item counts, GB volumes, file types, processing status
2. Review platform exports — document counts, reviewer IDs, coding dates, relevance/privilege/issue-tag designations
3. Search term results — hit counts per query, precision/validation sampling data if available
4. Privilege log drafts — finalized privilege assertions with custodian and document-type breakdowns

Quick Start

1. Normalize custodian names across all sources into a single canonical list
2. Populate each report section using the templates below
3. Surface flags and anomalies at each stage
4. Mark final output: ATTORNEY WORK PRODUCT — PRIVILEGED AND CONFIDENTIAL

Report Sections

1. Executive Summary

• Collection completeness status
• Search strategy effectiveness (one sentence)
• Review progress % and projected completion date
• Critical issues requiring immediate action

2. Collection Metrics by Custodian

Flags:

• Volume >2× matter average → possible over-collection or key player
• Unexpectedly low volume → incomplete collection risk
• Processing error rate >5% by custodian or file type

Validation: Collected ≥ Processed ≥ Loaded ≥ Reviewed. Explain any downward discrepancy.

3. Search Term Performance

Flags:

• Hit rate >30% → likely overbroad
• Hit rate <0.5% → likely underperforming
• High inter-term overlap → recommend consolidation
• If precision data exists, project relevant yield from unreviewed hits

4. Review Progress

Reviewer Productivity:

• Flag coding patterns >15% above/below team average (QC concern)
• Note velocity trend: accelerating / decelerating / stable (weekly rolling avg)
• Projected completion: [Date] at [N] docs/day — state assumptions explicitly

5. Privilege Analysis

• Note whether overall privilege rate is within expected range for matter type
• Break down privilege rate by document type (email vs. office docs vs. other)
• Flag custodians with rates >2× matter average for senior attorney QC

6. Recommendations & Timeline

• Resource needs: additional reviewers / vendor remediation / search refinement
• Search adjustments: specific terms to modify
• QC actions: reviewer-specific or category-specific
• Risk items: gaps, processing failures, tight deadlines
• Milestones: processing complete, first-pass review complete, privilege log ready (with dates)

Pitfalls

• Privilege substance leaks — present privilege statistics in aggregate only; never reveal communication substance or attorney mental impressions
• Adverse findings — report collection gaps, QC failures, and search weaknesses without minimization so counsel can make informed decisions
• Missing audit trail — document how discrepancies were resolved and what validation steps were taken; the process may be challenged
• Unstated assumptions — all projections must explicitly state their underlying assumptions
• Distribution control — limit report distribution to litigation team members with case management need