Document Review and Privilege Log

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.