The review team is ready, but one custodian’s archive has not arrived. A tracker that says “80% complete” does little to explain the consequence. Discovery coordination should tell counsel what is missing, who can retrieve it and which part of the production depends on it. This playbook follows that work through release under attorney direction.
Map the Work and Its Owners
Amendments to Federal Civil Rules 16 and 26, together with new Rule 16.1, took effect December 1, 2025. They are a reminder to build a matter’s plan from current rules and the actual orders in the case. Counsel should confirm which requirements apply and the deadlines the team will use.
Break each request into collection, processing, review, decisions, production preparation and delivery. Identify the person responsible for each stage and the information they need from the prior stage. Keep attorney decisions about relevance, privilege and objections distinct from administrative status updates.
Use an approved calendar for controlling dates. The tracker can display them, but it should also record who verified the date and the underlying rule, stipulation or order.
| Work Item | State | Next Decision |
|---|---|---|
| Custodian a Records | Ready for Review | Assign Reviewer |
| Custodian B Records | Privilege Review | Counsel Decision |
| Custodian C Archive | Collection Blocked | IT Restoration Plan |
| Production Set 1 | Awaiting Approval | Attorney Release Authorization |
Confirm the Production Instructions
Confirm counsel’s production instructions before preparing the export. Record the scope and required format, including numbering and redaction instructions. Ask the technical team to test a sample against those requirements. A production log should connect what is delivered to the records that were reviewed.
If a file fails conversion or a redaction is incomplete, record the exception and seek direction. Explain which document is affected and what correction is proposed. Keep the revised output available for review before it replaces the release copy.
Report Exceptions Before Release
Give counsel an update that supports a decision. Identify the remaining collection or review work and explain whether it affects the planned production. A missing archive needs a named retrieval owner and a realistic status update; repeating “IT is working on it” leaves counsel without information to act on.
Retain the approved production version and delivery evidence. Confirm the intended recipient and record any delivery failure. If the recipient reports a missing file, link that request to the production it concerns so the team can investigate the exact set that went out.