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Tech Tips
Developing an Export Strategy
The export phase of the electronic discovery process is arguably the most delicate.
The term "export" refers to the process by which electronic documents are transferred
from a centralized database where online review was conducted to some other location
or format for production. Whether you opt to produce documents electronically
or on paper, it is critical for your legal team to carry out the production in
the most efficient manner. The trick to successful exporting is to plan ahead:
Develop an export strategy before you begin your review process. The following
checklist can help you plan your strategy.
- Define Data Set
Define the data set to be produced. Some options include: all documents in the
database, responsive documents, non-privileged responsive documents, etc.
- Set Production Criteria
Establish and enforce criteria to properly code documents for production during
the review process.
- Define Document Export Rules Document Groups:
Many documents are said to belong to a group or family. In other words, one document
can be related to another document. For example, a zip file containing multiple
documents is a family group, as is an email with an attachment. Because the email
and the attached document are related, rules must be established as to whether
to produce one or both documents in the event that only one of the documents in
the group is found to be responsive. Established best practices dictate establishing
one rule and enforcing it without exception throughout the entire project.
Privileged Documents: Decide whether a privilege log is required, and determine
what categories of information will be included in the log.
- Bates Numbering and Document Branding:
At the beginning of the project, create a Bates number and branding format and
adhere to it throughout the project. Elements of a Bates number may include: prefix,
suffix, padding length and starting number. Branding considerations include: font,
placement, and fixed or dynamic content (e.g., page numbering).
- File Naming
Choose a file naming system for the produced documents such as the Starting Bates
number or Applied Discovery's internal Document ID number.
- File Output
Choose your file output options. The most common are PDF or TIFF with ASCII text.
- Document Reference Data
Meta data, privilege logs and cross reference files are commonly produced as a
companion to the actual document set. File type options for this data includes:
ASCII text, Excel, Access, etc.
- Output Media
There are four media types available for export: CD, DVD, FTP and hard drive.
The output media is typically dictated by the size of the data set to be exported
but can also be determined by court-mandated requirements and timelines. FTP is
the option most often used for productions of less than 1 GB—especially when a
quick turnaround is required.
Once the review portion of the project is complete and the documents are ready
for export, the next step is to ensure that all the export requirements are met.
Choose a service provider that utilizes standard quality control practices throughout
the review process and during the export process to verify the collection of documents
produced. A typical project should take less than 72 hours to produce, depending
on the number of documents, the amount of data, and the complexity of the project.
Developing a plan and setting requirements for the export process before the review
process begins is crucial to a project's success.
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Law Technology News Award
Applied Discovery recognized as Product of the Year and Best Electronic Data Discovery System by the readers of Law Technology News... 
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Newsletter
 Applied Discovery offers free subscriptions to The E-Discovery Standard™, our quarterly electronic discovery newsletter.
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New ABA E-Discovery Resource on FRCP Amendments
The Discovery Revolution: E-Discovery Amendments to the Federal Rules of Civil Procedure, by Lewis and Roca LLP partner George L. Paul, Esq. and J.H. Cohn LLP director of IT security auditing Bruce H. Nearon, CPA. Order your copy from the ABA today...
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