There are many methods of production. Your Litigation Response Plan must deal with how to decide on which method of production to use in different situations.

Will you produce in paper, TIFFs, PDF files or native files? A Native file is the actual file on the computer. For example, you would produce the actual Microsoft Word document, Excel document, or email to the opposing party.

Will you use a hosted solution?  A hosted solution allows the other side to actually use the web browser to review your files. So it is important in your Litigation Response Plan to discuss each of these methods, when you plan to use them, and what strategic choices should be made.

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