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What would you be random sampling? If you mean the documents your client gave you, then yes, you need to review every single document.
Make sure the tagging is correct, redactions are applied correctly, make sure all the documents you want to produce are actually being produced and anything you don’t want produced is not…
You need to, at a minimum, do a thorough privilege search. This may mean individual review if the batch is small enough or running a privilege screen based on privileged terms you decide on with your team and client. Responsiveness review then really is client dependent. Some clients are super protective over their documents and what to produce only what is absolutely necessary. Others don’t care as much, so producing some non-responsive documents in a larger batch may be fine. So really it depends on client, volume, and budget.
Depends. If the documents were hand collected based on a specific request (give me all the customer-facing documents for product X), you should be able to just ask the client if anything needs under the PO and not review. If, however, you are BigLaw, you review every page of every document, as how else are you going to get everyone their hours? ;)
Who do you think the client is going to blame if something goes wrong? Our job is to protect clients from themselves.
You go through every single document. If you have a problem billing for that, sit down, and actually brainstorm the various things your mind is doing, what your mind is referencing (your experience and law school training is a resource; controlling authorities), and make sure your billing entry captures the difficulty of the task while including the value added to the client.
Every doc. You can speed this up if you use systems like Relativity and can do searches to tag and slipsheet docs containing specific phrases like the names of attorneys. You can then go through those separately, usually at a later date, to confirm if they truly are privileged or should be produced. You can de-dupe in systems like Relativity too, which may not be permitted if the discovery request-order wants every version regardless of who the custodian is.
If your client sent you the docs to prepare for production, confirm whether they already scanned for privilege/work product. You should still be reviewing for that but it gives you an ideal of how likely it is you will see hits for that.
Whoever is in charge of the discovery productions should have a brief memo on what must be produced, what you might search for to tag for privilege or as withheld for other reasons, etc.
If you are that person, create one for yourself or at least a checklist. It will be a good memo to file as some CYA.
I review every document. If you have an unmanageable amount of documents then you should look into an ediscovery platform like relativity or DISCO (I use the latter). Although they can get pricey, it saves you a ton of time. Many have AI that recognizes socials, dob, and other PII and auto redact for you — many can create priv logs for you. If used correctly, they are powerful tools. Good luck!