Privilege-log a document production
Practice the sequence you already learned for “Privilege-log a document production” until the order feels automatic. Drill FRCP privilege-log order from litigation-support training. A withheld document is not produced or silently dropped; it is logged with the taught fields before the production ships.
- Identify each document withheld as privileged or work product.
- Record date, authors, recipients, and the privilege claimed.
- Describe the subject without revealing the privileged content.
- Have counsel review the log.
- Produce the non-privileged set.
- Serve the log with that production.
- Do not produce a privileged family member ‘to keep the email thread readable.’