Six Common Review and Production Problems: How to Fix Them August 2014 | Page 13
POTENTIAL ISSUE: Numbering is a more complex operation that requires
two things before beginning: all documents must be in order (generally,
email attachment should occur after the parent email – not all tools
automatically do this) and the type of numbering matters (i.e., by
document or by page? continuation of previous numbering? native and
images?). No matter how small, any changes to a production after
everything has been numbered may require going back and re-numbering
the entire production. For example, removing page 68 or document 52
(due to privilege or other concerns) would leave a gap that could be
questioned by the receiving party.
RESOLUTION : To avoid numbering a production multiple times, decide
upfront on a numbering schema and only apply that numbering once the
production is final.