# Disclosure Review Playbook

Use this reference for England and Wales disclosure-list QC.

## Review Mindset

Disclosure review is a coverage and risk exercise. It does not certify compliance. The output should identify gaps, weak inspection/privilege positions, and questions for the responsible lawyer.

## Coverage Map

Map each pleaded or ordered issue to:

- listed documents,
- likely sources/custodians,
- date ranges,
- search record if supplied,
- absent sources,
- documents referenced elsewhere but missing,
- status: `covered`, `partial`, `source_missing`, `not_assessable`.

Do not infer missing documents merely because they would be convenient. Tie every gap to a pleading, witness statement, chronology entry, document reference, search record, or order term.

## Custodian and Repository Gaps

Flag:

- named people in pleadings/statements absent from custodians,
- key repositories absent from search record,
- date ranges that stop before/after pleaded events,
- document classes expected from supplied sources,
- families/attachments not separately reviewed,
- duplicate or superseded drafts not explained.

## Privilege and Inspection

For withheld, redacted, or non-inspectable documents, record:

- document id/range,
- privilege or objection basis,
- author/recipient/copy list where available,
- date,
- description,
- whether attachment separately assessed,
- reason the basis is weak/unclear,
- next lawyer-review step.

Dominant purpose matters for litigation privilege. A document connected with litigation is not automatically privileged if its dominant purpose is business management or another non-litigation purpose.

## Adverse Document Triage

Use labels carefully:

- `potentially_adverse`
- `potentially_supportive`
- `neutral`
- `unclear`
- `not_assessable`

These are investigative leads, not admissions or merits findings.

## Output Sections

1. Materials reviewed and missing.
2. Pleaded-issue coverage table.
3. Custodian/source/date-range gaps.
4. Documents referenced elsewhere but absent.
5. Privilege, redaction, and inspection flags.
6. Potentially adverse/supportive document leads.
7. Rule/order points needing verification.
8. Questions for responsible lawyer.