Document review is, of course, a crucial phase in the production of discovery. Prior to the ascendance of computers, the documents involved would, typically, be contracts, letters, reports and other such documents, typed or handwritten and kept by the client in a file regarding the matter. If the documents filled an expansion folder, they were considered a large number of documents; if they filled a banker’s box, document production was considered huge.

Today, of course, the number of documents produced in discovery is considerably greater. There are two principal reasons for the increase, both due to the advent of computers. First, communications that were in years past verbal—in person, on the phone—are now done, or summarized after the verbal conversation, in emails and texts, driving up the number of responsive documents considerably. Second, since documents generated or received by computers are stored, usually on several devices and in backups, nonresponsive documents—a number usually considerably greater than that of responsive documents—must also be collected and searched to determine whether any or all are responsive are also stored.