In a case involving several complex claims and multiple parties, the review is going to be conducted by contract attorneys hired through an agency who will have no other role in the case. Counsel for the producing party will need to create a document to guide the review (protocol), providing rules for the review and setting out the coding scheme for the ESI to be reviewed. In designing such a coding scheme, there is an inherent tension between which two goals?

Select one:

a.

Identifying privileged material and identifying relevant material.

b.

Tagging the documents for various issues and identifying privileged material.

c.

Identifying relevant material and understanding the issues in the case.

d.

Efficiency of review and completeness of the tagging.