§ 01
DRD & scope
Sample-tested search terms, defensible source list, custodian schedule and cost model - all in a form counsel can put to the court.
§ eDisclosure · PD 57AD
eDisclosure services for the Business & Property Courts.
Disclosure in England and Wales is a regulated exercise, not a data-transfer task. We deliver PD 57AD-compliant eDisclosure with the forensic rigour a court demands and the timetable a case management order allows.
- Framework
- PD 57AD
- Courts
- B&PC · TCC · Comm
- Load formats
- Relativity · DAT · Native
- Privilege QC
- Two-layer standard
Ref · E-D · 2026 · §DISClass · ConfidentialJuris · England & WalesStatus · Active
Plate · Disclosure§ 01 · Audience
Who this page is for.
Litigation partners, associates and legal operations teams responsible for meeting a disclosure order, drafting a Disclosure Review Document, or defending a challenged disclosure position. The workflow below is the one we run for matters in the Business and Property Courts, the TCC and the Commercial Court.
- Litigation partners
Setting the disclosure strategy at CMC and defending it through trial.
- Associates & paralegals
Running the DRD, review workflow and production cadence day to day.
- In-house litigation counsel
Managing panel firms and needing an independent view of proposed scope and cost.
- Barristers' chambers
Preparing for interlocutory applications or trial with reference-ready disclosure.
§ 02 · The problem
Where UK disclosure goes wrong.
The failures we're asked to fix are consistent: an over-broad DRD, collections that IT did without forensic tooling, and a production format that doesn't match the load-file specification the parties agreed. Each is avoidable.
Risk
An over-broad DRD
Search terms and sources agreed without sampling produce review populations that blow the timetable and the budget. The court then orders re-scope, which slows the case further.
Risk
Non-forensic collections
Custodian mailboxes exported by IT lose metadata, message-thread integrity and, sometimes, deleted-item recovery. Once compromised, it cannot be un-compromised.
Risk
The wrong production format
A production delivered as PDFs when the order required native + metadata invites the other side to press for a re-production, on a timetable that no longer allows it.
Risk
Privilege bleed
A single missed privilege call in a production of tens of thousands of documents becomes a satellite dispute of its own. Two-layer QC exists for a reason.
§ 03 · Scope
The disclosure workflow, end to end.
From DRD to Disclosure Certificate, the same team runs every phase.
§ 02
Legal hold
Hold issued and tracked across M365, Google Workspace, Slack, Teams and endpoints, with acknowledgement records.
§ 03
Forensic collection
Hash-verified, ACPO-aligned capture. On-site UK-wide or remote. Endpoint, mobile, cloud and server sources.
§ 04
Processing & culling
De-NIST, dedupe, near-dupe, email threading, OCR and language ID before a single document is put in front of a reviewer.
§ 05
Hosted review
Relativity or equivalent, configured to the disclosure model with role-based access, privilege layers and QC gates.
§ 06
Production & certificate
Load-file production in the agreed format, metadata schedule, privilege log and Disclosure Certificate-ready audit trail.
§ 04 · Why e‑discovery.uk
Chosen where the disclosure will be tested.
Because our roots are in digital forensics, our disclosure work is built to survive a challenge on process, not just a challenge on substance.
PD 57AD fluency
Deep familiarity with the Disclosure Review Document, the disclosure models and the standard directions.
Forensic-led collection
Collections stand up under expert scrutiny because they are done by expert practitioners.
Two-layer privilege QC
First-pass reviewer coding is checked by a dedicated QC layer before production.
UK data residency
Working sets remain in the UK unless counsel and the client agree otherwise.
Signed deliveries
Every production ships with a signed delivery note and audit trail suitable for the Disclosure Certificate.
Independent status
We do not act for either side on the merits. The evidence handling is neutral by design.
§ 05 · Typical matters
Typical disclosure matters.
Contentious work across the Business and Property Courts and specialist lists.
- ▸High-value commercial disputes (Comm / B&PC)
- ▸TCC construction and infrastructure claims
- ▸Shareholder and warranty disputes
- ▸Fraud and asset-tracing claims
- ▸Employment disputes with disclosure at scale
- ▸International arbitration with UK-seated disclosure
- ▸Public inquiries and judicial review
- ▸Group litigation and representative claims
§ 06 · Deliverables
What we deliver.
The tangible artefacts that make disclosure defensible.
- Sample-tested DRD inputs
Search-term hit reports, source assessments and cost forecasts ready for the CMC.
- Hash-verified collection set
Forensically sound source data with acquisition notes and hash values.
- Reviewed & QC'd review set
Coded documents with privilege calls checked to a two-layer standard.
- Production set
Load-file compliant production with metadata schedule and privilege log.
- Disclosure Certificate pack
The signed audit trail counsel needs to certify disclosure.
- CPR Part 35 report on process
Where the disclosure exercise itself is challenged, an expert report from the supervising practitioner.
§ 07 · Frequently asked
Answers to the questions counsel ask most.
- What is the difference between eDisclosure and eDiscovery in UK practice?
- In UK legal usage, 'eDisclosure' is the term the courts use in PD 57AD for the disclosure of electronic documents in litigation; 'eDiscovery' is the broader international term that also covers regulatory investigations, internal reviews and arbitration. In practice the process - identification, preservation, collection, processing, review, production - is the same discipline. We use 'eDisclosure' when the audience is a court in England and Wales and 'eDiscovery' more broadly.
- How do you handle Standard Disclosure under PD 57AD?
- We work with counsel to complete the Disclosure Review Document (DRD), identify data sources and custodians, propose search terms and issue legal hold. We collect defensibly, process with aggressive early culling, host the review population, run first- and second-level review, and produce in the load-file specification agreed at the CMC. All steps are documented for the Disclosure Certificate.
- Can you assist with Model A, B, C, D or E disclosure?
- Yes. Model A (known adverse), Model B (limited disclosure), Model C (request-led), Model D (narrow issues) and Model E (train of inquiry) each drive different collection scope, review populations and cost profiles. We scope the technical work to whichever model the court orders, and can advise counsel on the practical implications of each option before the DRD is finalised.
- How do you approach the Disclosure Review Document (DRD)?
- We treat the DRD as an engineering brief, not a form-filling exercise. We stress-test the proposed sources, search terms and de-duplication approach against sampled data so the numbers put to the court are defensible. This avoids the common failure mode where an over-broad DRD forces the parties back to court to re-scope disclosure mid-review.
- Do you produce disclosure in the format the court expects?
- Yes. We routinely produce in Relativity load-file format, Concordance DAT/OPT, native + metadata, redacted PDF and other formats specified by the parties or the court. Every production ships with a metadata schedule, a privilege log and a Disclosure Certificate-ready audit trail.
- What does a rolling or continuous disclosure workflow look like?
- For long-running matters we operate rolling productions on an agreed cadence (weekly, fortnightly, milestone-driven), with reviewers working the queue continuously as new material is processed. Each tranche is version-controlled and referenced against the disclosure timeline so counsel can trace exactly what was produced when.
- How is privilege and confidentiality protected in review?
- Privilege terms are agreed with counsel and applied at multiple layers - search-term suppression, reviewer coding, second-level QC and, where warranted, a dedicated privilege team walled off from the substantive review. Confidentiality rings and access controls are configured in Relativity to match court orders.
- What happens if the other side challenges our disclosure?
- Because collection, processing and production are documented at each step, we can produce witness statements, screenshots and hash logs to answer challenges without disrupting the review timetable. Where a CPR Part 35 expert report is needed on the process, we can provide one from the practitioner who supervised the work.
Instruct the practice
Bring us in early.
Defensibility is built, not retrofitted.
Whether you are responding to a regulator, preparing for disclosure, or scoping an internal investigation, start the chain of custody with a short, confidential conversation.