Tips for organizing an email to client in which we discuss categories of documents produced, privileged items, work product items, and problematic documents? It’s a huge net

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Could you do it outline style? For example:
I. Emails
A. Produced
B. Privileged
C. Problematic

II. Next category of documents, repeat...

It would be tedious but potentially helpful for you as well.

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Not by email? This seems like a phone call waiting to happen.

smart

I actually don’t think so, at all. This is exactly the sort of thing that should not be dealt with in email, because of the certainty of omission and confusion. I would send a brief agenda before the call, have the call, then follow up with a list of action items.

Avoid email. Do it in Word, maybe even as a formal memo. If less formal, I would create a chronological table (index) and provide the docs (where possible under protective order). If you want something more formal, then do a write up analyzing the docs.

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