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Document Review and Privilege Log

Five documents and four sheets that resolve every person in the withheld set once, then write each entry to the elements of the privilege claimed.

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Privilege Log  ·  one entry, two ways

KES0004412 – KES0004413

The same withheld email, described the way a column layout produces and the way the elements require.

What a filled column produces

Author M. Ferreira    Recipients D. Whitlock

Type Email    Date 2024-03-11    Privilege A/C

Description Email providing legal advice.

Four columns filled. Nothing in it lets the reader test a single element of the claim, and two names carry no roles at all.

What the elements require

Email from in-house counsel to the VP Supply Chain conveying legal advice on the notice obligations under section 8 of the Amaranth cold-chain agreement, following the February shipment failures.

ElementEstablished by
A communicationEmail, named sender and recipient
Attorney and clientRoles carried, not just names
In confidenceNo third party on the header
For legal adviceSubject named, advice withheld

Eleven more words. The advice itself still never appears.

Local Civil Rule 26.2(a)(2)(A) in the Southern and Eastern Districts of New York asks four things about a withheld document. The type, the general subject matter, the date, and the author, addressees and any other recipients, with the relationship between those people where it is not apparent. Every template ships the first three and the names. The relationship clause is what a challenge turns on, and it is the one that gets dropped.

So this pack resolves the people before it writes a line of the log. Every author, addressee and copyee across the whole withheld set lands in a directory once, with an employer, a role, a counsel status and the entry count beside it. One unplaced consultant sitting on twenty-nine entries is then a single question with a single answer. A recipient at the opposing party's own domain surfaces as four entries to pull rather than four entries to argue about.

The log is also not where most of your protection lives. Federal Rule of Evidence 502(e) makes a clawback agreement binding only on the parties to it unless a court order incorporates it, while an order under 502(d) reaches any other federal or state proceeding. Absent either you are on 502(b), whose second element is that you took reasonable steps to prevent disclosure. That is a claim about your process, so the review record is a separate sheet.

One withheld set, the people in it resolved, and the four sheets that come out

The Participant Directory, the working Privilege Log, the Review Register and the Redaction Log.

Participant Directory

Built first, from the whole withheld set, before a single entry is written. Illustrative rows for a fictional commercial dispute.

PersonRoleRelationshipEffect on the claimEntries
M. FerreiraAssociate General CounselIn-house counselSupports214
P. RamanPartner, outside firmRetained 19 Feb 2024Supports from that date168
D. WhitlockVP Supply ChainClient employeeSupports where advice is sought331
T. KerrLogistics consultantThird partyBreaks confidentiality29
Unresolvedinfo@amaranthlog.comOpposing party domainDefeats the claim4
Unresolvedjhale@ (truncated)UnknownCannot be assessed11

One consultant, twenty-nine entries. Resolved per entry that is twenty-nine problems. Resolved once it is a single question, and the answer lands on all of them at the same time.

Four entries carry a recipient at the other side’s domain. Whatever else is true of those emails, they are not confidential. They come out of the withheld set rather than into a fight.

Privilege Log

Working version. The last five columns are internal and come off before service.

BatesClaimedDescriptionMissingStatus
KES0004412A/CEmail from in-house counsel to the VP Supply Chain conveying legal advice on the notice obligations under section 8noneWithheld
KES0006120WPMemorandum from outside counsel analysing exposure under the indemnity, prepared after the demand letter of 22 March 2024noneWithheld
KES0008801A/CEmail forwarding counsel’s view to an outside logistics consultant for comment on the delivery scheduleConfidentialityEscalated
KES0011277noneRecipient is at the opposing party’s domain. A lawyer on copy does not make it confidentialConfidentialityProduced
KES0013902A/CEmail to a partner at the firm two weeks before the engagement letter is datedAttorney-client relationshipEscalated

An entry with anything in the Missing column is not an entry yet. It is a question for a supervising lawyer, and it stays out of the served log until that lawyer answers it.

Both escalations are groups. One answer about the consultant clears twenty-nine rows. One answer about the retention date clears every communication before 19 February.

Review Register

Nothing here is served. It is the record of how the review was actually run.

BatchCustodianDocsWithheldSecond levelSampledErrors
B-01Whitlock61217P. Raman612
B-02Whitlock70834P. Raman711
B-03Ferreira54449P. Raman540
B-04Voss48718P. Raman493
B-05Raman30151P. Raman300

Batch four failed its sample and was re-reviewed in full. Correcting three entries and moving on is a different answer to the question of whether the process was reasonable, and this row is where that answer is kept.

Every batch is sampled at the same rate. Raising it on the batches you already suspect tells you what you knew and leaves the rest unmeasured.

Redaction Log

A separate sheet, because a redaction is a production with a hole in it rather than a withholding.

BatesPageBasisWhat is behind it
KES00123112 of 9Work productCounsel’s marginal comment on the indemnity in section 11
KES00123145 of 9Work productCounsel’s marginal comment on the notice period in section 8
KES00094021 of 3Personal dataHome address and mobile number of a non-party employee
KES00147701 of 1Attorney-clientAttachment name that states the legal question counsel was asked

The personal-data row is not a privilege basis. Filing it under a privilege heading with the others invites a challenge to all four at once, so it carries its own label.

The last row hides the existence of a document rather than its content. That one points at the log entry where the attachment itself is withheld, so the two records agree.

What's in the pack

01

Participant Directory

Every author, addressee and copyee across the withheld set, resolved once into a role, a relationship and an entry count.

02

Privilege Log

Entries written to the elements, with internal columns recording which elements each description establishes and which it does not. It is served alongside the written response carrying the withheld count against each request.

03

Review Register

A row per batch: custodian, counts, reviewer, second-level reviewer, sample size and sample errors. Nothing here is served.

04

Redaction Log

A separate sheet, with non-privilege bases labelled as such so a challenge to one does not reach all of them.

05

Privilege Criteria

The elements of each claim, and the three descriptions that show exactly where a sufficient one starts.

06

Log Entry Standard

The sentence shape every description follows, so two hundred entries read alike and the odd one is visible.

07

Clawback Position

Which of the three states you are actually in, answered before the first batch rather than after something slips.

08

Review Protocol

Sources, search terms, review levels and the sampling rate, written down before the outcome is known.

How to use it

  1. 1

    Open in River, or take it blank

    Open the pack in River and hand it the withheld set, or download the Word documents and CSV sheets from the template library and work them yourself.

  2. 2

    Say which court you are in

    The federal rule sets a standard rather than a column list. What your log has to carry comes from the local rule, your judge's practices, or the order in the matter.

  3. 3

    Resolve the people first

    Every name in the set gets an employer, a role and an entry count. The ones nobody can place are reported as groups, largest first, rather than one at a time.

  4. 4

    Read it as opposing counsel, then serve

    Sort for the cheapest challenges the way they will. Anything still escalated stops the production until a named lawyer answers it.

Frequently asked questions

Is this template free?

Yes. The zip is Word documents and CSV sheets, no account and no card. Edit with AI is the other half: the agent reads your withheld set, resolves the people in it, and drafts entries to the elements. Other packs sit in the template library.

What format are the downloaded files?

Word (.docx) for the five documents and CSV (.csv) for the four sheets, zipped together. Excel, Numbers and Google Sheets open the directory and the logs straight off the download. Most review platforms import and export the same CSV.

Do the federal rules prescribe these columns?

No, and that surprises people. Federal Rule of Civil Procedure 26(b)(5)(A)(ii) asks only for a description that, without revealing the protected material, will enable other parties to assess the claim. It never uses the phrase privilege log. Columns come from your local rule or the order in your matter.

Can I serve a categorical or metadata log instead?

Often, and in some districts it is presumptively proper. Local Civil Rule 26.2(c) in the Southern and Eastern Districts of New York encourages both. A party cannot object solely because a log is categorical or metadata-based, but may object if the substantive information is not in comprehensible form.

Does it decide whether a document is privileged?

No, and the Elements Missing column is how that is enforced. Every entry carries the elements its description establishes and the ones it does not. Anything with a gap is escalated with the missing element named, and a review with escalations open does not go out.

We already have a review platform. Does this replace it?

No. Your platform holds the documents, runs the searches, and suppresses near-duplicates the way any matcher with a documented blind spot does. This is the layer above it: the directory the log reads its roles from, the elements each entry has to reach, and the record of how the review was run. Before any of it, check the load file the volume arrived on.

How is this different from reviewing a contract?

Different job entirely. Reading inbound paper against positions your firm already holds is about applying a settled view to one document. This is about proving a claim over thousands, to a reader whose whole interest is in finding the entry that does not hold.

Start with the people, not the documents

Take the Word documents and CSV sheets blank, or open this exact pack in River and hand it the withheld set.

Edit with AI