Purpose of the Template
When you receive an ESI production request, you must respond with technical specifications that meet Federal Rules of Civil Procedure requirements without overextending your resources. The Sedona Conference has released Technical Specifications for the Production of Electronically Stored Information (open for public comment through October 16, 2026) that provide a standardized framework for these negotiations.
This template adapts that framework into a working document you can customize and send to opposing counsel. It addresses the three production format options (Native, Image, or Hybrid), establishes metadata requirements, and handles modern ESI sources like messaging apps and social media.
Why you need this: Courts rarely grant a production "do-over" if your initial format is usable but not optimal. Getting the specifications right the first time prevents costly re-production and disputes about whether you've met your obligations.
Preparation Steps
Before customizing this template, gather:
- Your review platform's native format support (can it handle MSG files, XLSX with formulas, etc.?)
- Volume estimates by data type (email vs. structured data vs. messaging apps)
- Your metadata extraction capabilities (what fields can you reliably produce?)
- Any hyperlinked document protocols you've agreed to in your meet-and-confer
Identify which ESI sources are in scope. The Sedona specifications address paper, email, non-email files, social media, messaging applications, structured databases, and hyperlinked documents.
The Template
ESI PRODUCTION SPECIFICATIONS
Case: [Case Name and Number]
Producing Party: [Your Organization]
Date: [Date]
1. PRODUCTION FORMAT ELECTION
We will produce ESI in the following format:
[ ] Native Format (specify file types): _________________
[ ] Image Format (TIFF or PDF)
[X] Hybrid Format (Images for email/Office docs; Native for spreadsheets,
databases, and specialty files)
2. METADATA FIELDS
The following metadata will be provided in a delimited load file:
UNIVERSAL FIELDS (all ESI types):
- BegBates (production number assigned to first page)
- EndBates (production number assigned to last page)
- BegAttach (production number of first attachment)
- EndAttach (production number of last attachment)
- PageCount
- NativeFileName
- NativeFilePath
- DateCreated
- DateModified
- Author
- Custodian
EMAIL-SPECIFIC FIELDS:
- EmailTo
- EmailFrom
- EmailCC
- EmailBCC
- EmailSubject
- EmailDateSent
- EmailTimeZone
- AttachmentNames
MESSAGING APP FIELDS (if applicable):
- MessageThreadID
- MessageSender
- MessageRecipients
- MessageTimestamp
- MessagePlatform (e.g., Slack, Teams)
3. PRODUCTION MEDIA
ESI will be delivered via:
[ ] Encrypted external hard drive
[X] Secure file transfer (specify service): _________________
[ ] Cloud-based review platform transfer
4. LOAD FILE FORMAT
[X] Concordance DAT file (delimited text)
[ ] CSV with specified delimiter: _________________
Encoding: UTF-8
5. NATIVE FILE HANDLING
For documents produced in native format:
- Natives will be stored in a separate \NATIVES\ folder
- Load file will contain relative path to native file
- Placeholder images will be provided for native-only productions
6. HYPERLINKED DOCUMENTS
[X] [Cross-reference](/glossary/cross-reference) file linking parent Bates to linked file Bates
[ ] Treat as attachments (linked files follow parent)
[ ] Hyperlinks preserved in native format only
7. STRUCTURED DATA (Databases, Spreadsheets)
- Databases: [Specify export format, e.g., CSV with data dictionary]
- Spreadsheets with formulas: Native format with formula preservation
- Pivot tables and macros: [Specify handling]
8. SOCIAL MEDIA AND MESSAGING APPS
Meet-and-confer required for:
- Platform-specific metadata requirements
- Thread reconstruction methodology
- Handling of deleted/edited messages
- Treatment of reactions, emojis, and inline media
9. REDACTIONS
[ ] Redacted text will be replaced with redaction placeholder
[X] Separate privilege log will identify redacted material by Bates range
Redaction format: [Black boxes on image / Native file removal]
10. PRODUCTION CERTIFICATION
Each production will include a certification statement identifying:
- Custodians and data sources included
- Date range of documents
- Search terms or filters applied
- Any technical limitations or exceptions
Customization Guide
Section 1 (Format Election): Choose based on your review platform's capabilities and the opposing party's needs. If they're using basic review software, images may be safer. For complex spreadsheets or CAD files, use Native or Hybrid.
Section 2 (Metadata Fields): The template includes fields from the Sedona Conference Appendix A. Remove fields you can't extract reliably. For example, if your email archive doesn't capture time zones, remove EmailTimeZone rather than produce blank values.
Section 6 (Hyperlinked Documents): The Sedona specifications don't mandate how to handle these, only that you address them. The cross-reference file option is less burdensome than treating every link as an attachment, but confirm your opposing counsel can work with it.
Section 8 (Modern ESI): This section requires a separate meet-and-confer because messaging apps and social media don't fit traditional email paradigms. Don't commit to a production method here; use this section to flag that additional discussion is needed.
Validation Steps
Before you send this specification:
Technical review: Have your eDiscovery vendor or IT team confirm you can actually produce the metadata fields you've listed. Don't promise EmailTimeZone if your archive doesn't capture it.
Load file test: Produce a small sample set (50-100 documents) and verify the load file imports correctly into a standard review platform. Check that Bates ranges are continuous and attachment relationships are preserved.
Format compatibility check: If you're producing natives, confirm the file types are readable without specialized software. A .PST file is useless to opposing counsel if they don't have Outlook.
Privilege workflow: Verify your redaction method doesn't accidentally produce metadata that reveals privileged content (for example, subject lines on redacted emails).
Meet-and-confer confirmation: Send this template before your Rule 26(f) conference, not after. The specifications should inform your discussion, and you'll need to adjust based on opposing counsel's objections or technical constraints.
The Sedona Conference specifications are designed to reduce transaction costs by giving parties a common starting point. This template translates that framework into a working document. Customize it for your case, but don't skip the validation steps. A technically sound production specification protects you from disputes and prevents expensive re-production down the line.
