In today’s complex litigation landscape, success isn’t just about having a strong legal strategy – it’s also about how well the eDiscovery process is planned and executed. Even the best legal teams can run into unnecessary risk, delays, or escalating costs if the discovery process isn’t managed thoughtfully from the very start.
When teams have a clear roadmap – knowing what needs to happen, when it should happen, and who is responsible – they are able to move matters forward efficiently and defensibly. This kind of planning is especially critical for project managers, legal operations professionals, and teams developing Standard Operation Procedures (SOPs) for document review and case management. A well-structured eDiscovery plan not only keeps projects on track but also builds confidence across internal teams, external counsel, and clients by reducing surprises and ensuring that every step supports the overall case strategy.
Start with a Clear Roadmap
Every successful eDiscovery project starts with a clear, structured roadmap that defines objectives, timelines, and responsibilities. Taking the time to plan at the outset helps avoid confusion, reduce risk, and keep the team aligned as the matter progresses.
Early alignment among key stakeholders – including attorneys, paralegals, IT teams, and legal ops professionals – is critical. By coming together at the start, teams can clarify case priorities, understand the scope of potentially relevant data, and agree on how they’ll work together throughout the process.
At this stage, it is essential to:
- Define project scope and objectives early - outline what “success” looks like, including deliverables, timelines, and any legal strategy considerations
- Identify custodians and data sources – know where to collect from and what systems may hold information.
- Review data retention policies and potential compliance requirements to avoid missteps that could create risk later on.
- Establish early communication channels for internal updates and client reporting to keep everyone informed and aligned.
When everyone understands the scope, expectations, and processes before any documents are collected or processed, projects run more smoothly and defensibly. This upfront effort creates a foundation for efficiency and helps ensure that decisions made later in the process are informed and strategic.
Preservation and Collection: The First Action Steps
Once the roadmap is established, preservation becomes the first critical step. Before anything can be collected or reviewed, it is essential to protect relevant data from being altered or deleted. This step is foundational to defensibility and helps prevent costly issues later in the matter.
Typically, legal teams will issue preservation notices or hold orders to custodians, ensuring they understand their obligations and that all relevant information is protected. This process often requires close coordination with legal ops and IT to confirm compliance and keep thorough documentation every step of the way.
After preservation is secured, the focus shifts to the collection phase. This involves gathering relevant ESI from the sources identified during planning. This may include email systems, cloud platforms, file servers, mobile devices and other repositories.
A well-executed collection process does more than just gather data; it reduces risk, maintains a clean chain-of-custody, and lays the groundwork for an efficient review process. By taking a thoughtful, structured approach at this stage, teams set themselves up for smoother downstream workflows and a defensible discovery process overall.
Processing: Making Data Manageable
Before any documents can be reviewed, they need to go through processing. This phase helps teams reduce volume by eliminating de-duplicate files, filtering out irrelevant data, and converting files into consistent, review-ready formats.
With a well-planned approach, processing not online streamlines the data but also sets the foundation for defensibility and efficiency throughout the rest of the eDiscovery project. A well-defined and, where possible, automated workflow helps avoid costly rework and bottlenecks later on – ultimately saving both time and money.
Processing also serves as an early checkpoint to validate metadata integrity, catch potential issues before they escalate, and implement analytics or search strategies. These proactive steps allow teams to prioritize the most relevant information early, giving legal teams better insight into the data landscape and enabling smarter, more strategic decision-making as the matter moves into review.
The Review Process: Efficiency and Accuracy
The review process is often the most resource-intensive and costly stage of an eDiscovery project. This is where lawyers and review teams carefully examine documents for relevance, privilege, and confidentiality, ensuring only the right information moves forward for production.
Because of the high stakes, planning ahead is critical. Thoughtful preparation helps define:
-
Who will conduct the review – whether it’s internal counsel, outside counsel, or a dedicated review team.
-
How technology-assisted review (TAR) or Active Learning will be leveraged to accelerate review and prioritize key documents.
-
How review assignments and progress will be tracked, reported, and quality-checked to ensure accountability and defensibility.
A well-structured workflow at this stage minimizes delays and errors, while also providing visibility into progress and costs. It’s not just about moving documents through the pipeline – it’s about building confidence for both the legal team and the client that every step is defensible, efficient, and aligned with case strategy.
Strong communication between legal teams, project managers, and review teams is also essential. By aligning on review protocols, decision-making guidelines, and escalation processes early, you reduce the risk of rework and avoid costly surprises down the road.
When managed effectively, the review phase becomes a strategic advantage – enabling faster insights, stronger case preparation, and more informed legal decisions, all while maintaining control over timelines and budgets.
Production and Delivery: Completing the Workflow
Once review is complete, the final step is to prepare and deliver documents for production. This stage involves carefully formatting files to meet court or regulatory requirements, ensuring metadata integrity, and delivering files securely to opposing counsel, regulators, or other parties.
Production is often the most visible stage of the eDiscovery process, so attention to detail is critical. A single error, like missing metadata or incorrectly formatted files, can create significant risks and delays.
By defining production timelines, responsibilities, and approval processes in advance, teams can prevent last-minute surprises and reduce the likelihood of rework. Clear planning also ensures stakeholders know exactly what to expect and when, building trust and confidence in the process.
When executed well, production isn’t just the final step in the workflow – it’s the moment where all prior planning and effort come together, ensuring a seamless, defensible closeout of the matter.
Integrating SOPs and Legal Ops Best Practices
For legal teams looking to build or refine their SOPs, mapping these stages into repeatable and scalable workflows is critical. This creates clarity, consistency, and efficiency across matters.
Legal ops play a pivotal role here, helping to standardize templates, checklists, and approval processes so that every project follows the same clear, defensible framework. When lessons learned from past projects are captured and built into your SOPs, you’re not just solving today’s challenges – you’re laying the foundation for smoother, more predictable future matters.
The benefits of well-integrated SOPs include:
-
Reducing administrative burden and rework, freeing teams to focus on higher-value tasks.
-
Increasing consistency across cases and matters, ensuring no critical steps are missed.
-
Enable faster onboarding for new team members by providing clear guidance and structure.
-
Maintaining a defensible and auditable record of the eDiscovery lifecycle for compliance and risk management.
At the end of the day, strong SOPs don’t just keep projects on track, they empower teams, support better decision-making, and create confidence for both internal stakeholders and clients.
Why Planning Matters
The ultimate goal of eDiscovery planning is not just to check boxes – it’s to build a clear, defensible roadmap that gives teams confidence at every stage, from data collection through review and production. Thoughtful planning creates the structure needed to work efficiently, reduce risk, and avoid last-minute surprises, freeing legal professionals to focus on what matters most: strategy and substance of their case, not administrative hurdles.
At Array, we help legal teams implement end-to-end eDiscovery workflows that translate planning into action. From initial data collection to large-scale document review and production, we provide the infrastructure, technology, and expertise to support projects of any scale. Our approach empowers legal ops teams and project managers to create repeatable, efficient processes that keep cases on track and outcomes defensible.
Final Thoughts
Planning an eDiscovery project is both an art and a science. When every stage of the process is clearly mapped out and best practices are built into SOPs, legal teams are able to streamline workflows, minimize errors, and maintain defensibility throughout the lifecycle of a matter.
At the end of the day, thoughtful planning isn’t just operational hygiene – it’s a strategic advantage. It helps organizations work smarter, manage costs, reduce risk, and stay ahead of deadlines, while giving teams the confidence that nothing important will slip through the cracks.
For any legal team navigating complex litigation, effective eDiscovery planning remains a cornerstone of success – ensuring that resources are used widely and outcomes are both efficient and defensible.
