Free · twelve checks · about 10 minutes
The protective-order checklist: twelve checks before any outside vendor sees a page.
Run it with the order and the vendor's paperwork in front of you. It works for any vendor, including this one.
This is a checklist, not legal advice. Your order and your judge control.
The order's scope reaches the vendor.
Read who the order lets see confidential material. Orders often name counsel, experts and consultants; confirm a document vendor fits one of those, or add it by stipulation. If the order is silent, settle it before anything moves.
The vendor signs the order's acknowledgment form, or an equivalent.
If the order attaches an acknowledgment or undertaking, the vendor signs that form, not only its own NDA. Keep the signed copy in the file before the first page goes out.
Tessera Signs the order's vendor acknowledgment before anything is transferred.
You know every subcontractor.
Ask who else touches the data: staff, contractors, an outside review team, a hosting company. Each one is a person under the order and needs to sign or be covered.
Tessera None. Kevin Matos handles every matter himself.
You know where the data sits, and that it stays offline.
Ask for the physical location, and whether any page, excerpt or metadata goes to a cloud service or an AI model. A “secure cloud” is a third party, so get its name.
Tessera An air-gapped computer Tessera owns, with no internet connection and no cloud AI.
Access is limited to named people.
Get the names of everyone who will see the documents, not a team or a department. The list should match the signatures from check 2.
Tessera One name, Kevin Matos.
The transfer method is agreed in writing.
Agree how the pages travel in and back: your own secure file share, an encrypted link, or an encrypted drive by courier. Never as email attachments, and the password goes by a different channel than the file.
Tessera Your file share, an encrypted link at no cost, or an encrypted drive by courier for large sets.
Return or destruction has a date, a log and a certificate.
Set the date the vendor returns or destroys the documents, every copy and everything derived from them. Ask for a chain-of-custody log from receipt to destruction, and a signed certificate at the end.
Tessera Destruction at close, a signed certificate, and a custody log kept from receipt.
Privilege and clawback are covered.
Leave privileged material out unless the work needs it. If the order has a clawback or inadvertent-production clause, the vendor agrees to stop, tell you, and return or destroy on notice.
Tessera Follows the order's clawback terms. Where the order and Tessera's terms conflict, the order controls.
The conflicts check is done.
Give the vendor the names of the parties and ask whether it works, or has worked, for anyone on the other side. Get the answer in writing before the documents move.
You know what insurance stands behind the vendor.
Ask whether the vendor carries professional liability (errors and omissions) and cyber coverage, and ask for the certificate. If it carries neither, know what its liability cap is.
Tessera Does not yet carry E&O or cyber coverage. Liability is capped at the fee paid (section 9).
The vendor talks only to you.
The vendor reports to you, or to the expert working for you, and to no one else about the matter. If a subpoena or other demand for the materials arrives, it tells you promptly so you can object.
Tessera Works at counsel's direction, reports only to counsel (section 7), and gives that notice unless the law forbids it.
The vendor follows the order as the court changes it.
Orders get amended and designations get challenged. The vendor agrees to follow the order as modified from the day you tell it, and you have a way to reach it the same day.
Tessera Follows the order, and the order controls over Tessera's terms.
Each Tessera line is how Tessera answers that check under its terms , section 6 unless noted. Ask any vendor for the same answers in writing.
Four free ways to see the work first
Each one is useful on its own, whether or not you ever start a matter.
The Hidden-Transfer Sheet Twelve patterns that show up in contested productions, how to spot each on a statement page, and what to ask for next. Rules and cases cited. Get the sheet The Tie-Out Template A free Excel workbook that ties a fiduciary account or a net worth statement to the bank records. Fifteen checks, no macros. Get the template A 20-minute read of your production Tell me about the set; no documents change hands. You get a one-page read: what's likely missing, what to check first, and whether this fits. Ask for a read A free index of 50 pages Send up to 50 pages from a live production. In 48 hours you get a cited index and up to 10 first findings, run the same way as a paid matter. Request a free index
Evidence Sweep
Fixed-fee offline analysis of financial productions for New York litigators and forensic accountants. Every figure cited to its page and line in 72 hours.