The Document Review Checklist Every Paralegal Needs

Document review is where most of the time and money in e-discovery is spent. It's also where the most consequential decisions happen — which documents get produced, which are withheld as privileged, and which are flagged as key evidence. A structured approach makes the difference between a review that's defensible and efficient and one that's chaotic and expensive. Here's the checklist.

Phase 1: Preparation

Before reviewing a single document, invest time in preparation. Skipping this phase is the most common reason reviews go sideways.

• Understand the case — Read the complaint, answer, and discovery requests. You need to know what's at issue to determine what's relevant.
• Get a review protocol from the attorney — The supervising attorney should provide clear guidance on what counts as responsive, what privilege issues to watch for, and what confidentiality designations apply.
• Define your tags — Establish your tagging taxonomy before review starts. At minimum, you need: Responsive, Not Responsive, Privileged, and Confidential. Some cases may need additional tags like "Hot Document," "Key Custodian," or issue-specific tags.
• Identify key players — Create a list of key custodians, opposing parties, and other important individuals. Knowing who matters helps you recognize relevant documents faster.
• Note key date ranges — Most cases have a relevant time period. Knowing it helps you prioritize and identify documents outside the scope.
• Set up your workspace — Ensure all documents are loaded, OCR has been applied to scanned files, and the review platform is configured with your tags and filters.

Phase 2: Organize by custodian

Documents should be organized by custodian — the person whose files they came from. This is standard practice for several reasons:

• Context — Reviewing one custodian's documents together helps you understand the narrative and spot relevant patterns
• Privilege analysis — Privilege depends on the relationship between sender and recipient. Custodian-based review keeps this context intact.
• Production tracking — Courts and opposing counsel often expect production organized by custodian with a source log
• Prioritization — Start with the custodians most likely to have relevant documents. The supervising attorney can help you rank them.

Phase 3: Search strategies

Don't review every document linearly. Use search to focus your review on the most likely relevant documents first.

• Keyword searches — Start with the obvious terms from the discovery requests, contract names, project names, and key phrases
• Boolean operators — Use AND, OR, and NOT to refine. For example: "termination" AND "agreement" is more targeted than searching for either term alone.
• Date filters — Narrow to the relevant time period to reduce noise
• File type filters — If you're looking for contracts, filter to PDFs and Word documents. If you're looking for financial data, filter to spreadsheets.
• Custodian filters — Combine keyword searches with custodian filters to review one person's relevant documents at a time
• Iterative refinement — Start broad, review a sample, then refine your search terms based on what you find. Document your searches for defensibility.

Phase 4: Tagging workflow

Consistent tagging is the backbone of a defensible review. Here's a standard tagging framework:

Best practices for tagging:

• Tag every document — Don't leave documents untagged. An untagged document is a document with an unknown status, which creates risk.
• Tag in one pass when possible — Apply all relevant tags (responsiveness + privilege + confidentiality) in a single review pass to avoid re-reviewing
• Flag uncertain documents — If you're unsure about a privilege call or relevance determination, flag it for attorney review rather than guessing
• Review families together — An email and its attachments should be reviewed and tagged as a unit. Don't produce an attachment without its parent email.

Phase 5: Quality control (QC) review

QC is not optional. Every production should include a quality control step.

• Sample check — Pull a random sample of documents tagged as "Not Responsive" and verify the calls. Do the same for "Responsive" documents.
• Privilege review — Have the supervising attorney review all documents tagged as privileged. Improper privilege claims can result in clawback issues and credibility damage.
• Consistency check — Look for inconsistencies. If an email chain is tagged as responsive but one message in the chain is tagged as not responsive, investigate.
• Gap analysis — Check for untagged documents, missing custodians, or date ranges with suspiciously low document counts
• Hot document review — Ensure key documents flagged during review have been brought to the attorney's attention

Phase 6: Production preparation

Once review and QC are complete, prepare the production:

1. Build the production set — Collect all documents tagged as responsive (minus privileged documents) into a named production set
2. Apply Bates stamps — Number every page sequentially with the agreed-upon prefix and format
3. Prepare the privilege log — List every withheld document with the date, author, recipients, subject, and basis for the privilege claim
4. Create the production cover letter — Document what's being produced, the Bates range, the format, and any applicable confidentiality designations
5. Final spot-check — Open several documents in the production to verify Bates stamps are applied correctly, pages are complete, and redactions (if any) are properly applied

Common pitfalls to avoid

• Starting review without a protocol — This leads to inconsistent tagging decisions that are hard to fix later
• Ignoring document families — Producing an email without its attachments (or vice versa) creates confusion and may require supplemental production
• Skipping QC — Producing privileged documents by mistake can waive privilege protection, even with a clawback agreement
• Not documenting search terms — If opposing counsel challenges the adequacy of your review, you need to show what searches you ran and why
• Reviewing without context — A document that seems irrelevant in isolation may be critical when you understand who the custodian is and what role they played

How Athens Search supports document review

Athens Search provides every tool a paralegal needs to execute this checklist efficiently:

• Tagging — Built-in tags for Responsive, Privileged, Confidential, and Not Responsive, with the ability to add custom tags
• Full-text search — Boolean search with filters for custodian, date range, and file type
• Custodian management — Documents organized by custodian from the moment they're imported
• In-browser review — View and tag documents directly in the platform without downloading
• Production sets — Build named production sets from tagged documents and apply Bates stamps in one step
• Role-based access — Control who can view, tag, and produce documents with granular permissions