Plan civil document discovery with a production checklist. Cover custodian lists, date ranges, core paper files, email and chat ESI, phones and backups, accounting systems, contracts, insurance, photographs, and privilege-log expectations so requests for production and ESI protocols match the case theory. Use it with a request-for-production form and an eDiscovery source list. For litigators and paralegals. This is not legal advice; scope, proportionality, and local ESI rules differ—confirm current rules of civil procedure and any standing order before you serve requests.

Interview the client about who had the documents. Do not invent a ten-year range without a reason.
Ask where boxes live (office, warehouse, home). Photograph tabs before scanning if chain of custody matters.
Record the vendor (Microsoft 365, Google, Slack). Note legal-hold status.
Include departed-employee archives. Flag encryption or BYOD issues.
Export formats and who can run them. A screenshot is not a substitute for the ledger.
Common in tort and property cases. Ask for native photo metadata if authenticity will matter.
Align with local rules. Identify counsel communications that should be withheld, not produced and clawed back later.
State this in the RFP instructions or a separate ESI protocol.