This page lists three turns, the messages you send to the AI one after another in the same chat, and then a check of the answer. Keep it open next to your chat. Each turn shows the next thing to paste, with the values you entered already filled in. Nothing is sent from this page, and your conversation stays in the AI tool you are using.
Posture, claims, and the story the documents need to support or defeat.
Who was collected, from what sources, and how much is left after dedup and threading.
The issues that matter, in priority order. The protocol will cut this to three.
The court, the governing ESI protocol, the 502(d) order, and the privilege log requirements.
What you are actually reviewing on, with how many people, for how much, by when.
Watch for these throughout
The ESI protocol or stipulated order controls search terms, formats, dedup, and threading. Read it before deploying anything here. A protocol that conflicts with the order is a motion waiting to happen.
Search strings are hypotheses. Run hit reports and sample the results before locking terms. Every volume estimate this produces is a guess, not a measurement.
An FRE 502(d) order reduces the consequences of an inadvertent production; it does not cure a careless privilege review, and it does not relieve you of the log requirements under FRCP 26(b)(5) and your local rules.
Cross-border collections implicate GDPR, blocking statutes, and works council consultation. Confirm the legal basis before data leaves the jurisdiction.
This protocol assumes linear or hybrid review. Technology-assisted review needs its own validation protocol and, in most courts that have addressed it, disclosure to the requesting party.