Karen Kent is a paralegal working on a large document production. Karen has no idea what the case is about but is asked to review and stamp some documents that will be copied and produce for the opposing counsel.
What kind of documents should Karen look for that might legitimately be withheld?
What is the best way to "flag" these documents?
Should she attach post-it notes to them?
Mark them in pencil?
What should she do after she has identified and isolated them?
In this scenario the paralegal really ought to be given sufficient instructions before she begins.
To understand the issues of the case, the supervising attorney should brief the paralegal on the issues in the case and advise as to what the privileged documents will likely be.
Once these instructions are reviewed, the paralegal should review the documents for the following in particular:
1. Any correspondence between ...
Improper supervision of the paralegal and other issues are highlighted.