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1.7.2 Notable Factors

There are eight notable factors:

1. All RFP responses refer to a supplemental production number and a DCN range
2. All incoming documents are given DCNs if not already labeled and OCR’ed
3. Metadata is carefully managed to avoid inadvertent production of work product
4. Gaps in Bates numbers are handled, not avoided
   • Irrelevant documets are placed into ‘Irrelevant’ Library and not produced in discovery; there will be gaps in the numbering, but documents are irrelevant and not produced;
5. Original compilations of records are given DCNs but left in pristine, original condition
6. Lists are databases with which we build witness lists, chronologies, exhibit lists, and much more
7. Document folders are easily downloaded to Trial Pad
8. Sharing and utilization is tracked to avoid unnecessary discovery disputes