Resource
What to expect from a records review on a defense file
Four testable properties: facts cited to their pages, missing pages as a floor, reversible dedup, one set.
Facts linked to their source pages
One property separates a working chronology from a decorative one: citation. Checking a statement takes one click.
Pick ten entries at random and open each one’s page. Ten minutes is the standard; an afternoon is a failure.
A statement that cannot be matched to a page is held out, not delivered uncited, and the review says so.
Missing pages, stated as a lower bound
A production testifies to its own completeness twice. The producer’s stamp sequence, and the documents’ own “Page n of m” footers. Both prove a page is absent; neither proves how many.
The only finding that survives a custodian’s reply is a floor: at least N pages did not arrive. The method and the wording are in how to find missing pages.
This is a finding about pages. A document merely mentioned in the records is not what it answers. Every page too degraded to read is netted out before the claim is made.
Duplicates removed reversibly
Large productions repeat themselves. A unique page wrongly removed is gone from the set the file is worked from.
- Borderline pages are kept, not removed. Two pages close enough to be genuinely uncertain are both kept and flagged.
- Every removal is visible and reversible. The pages taken out come back with the set, each stamped with what it duplicated.
A removal rate published without a removal log is the flattering number without the checkable one.
One set, stamped and indexed
One record set, ordered by service date, Bates-stamped, and indexed by number, date, provider and source page.
Productions from several custodians belong in that one set, with each page’s origin tracked. Pages with no readable date keep their order at the end.
Five questions to ask before you buy
- Is every fact cited to a page, and what happens to one that is not?
- How are missing pages reported, as a count or as a floor? A count is a finding you cannot defend.
- Do the removed duplicates come back with the set?
- What is reported about pages you could not read?
- Who reviewed it, and what does the review cover?
What Claracord delivers
Every fact is cited to its page; a fact that cannot be matched to a page is not delivered. The record set comes back deduplicated, indexed and Bates-stamped with every removed page. The completeness report states missing pages as a lower bound. Human-verified.
Work product for the retaining professional: not legal or medical advice. Sold only to licensed legal and claims professionals, checked before any file moves.
The page for defense firms and panel counsel is insurance defense. A complete sample is on the home page. Synthetic demo case.