E-discovery can seem Kafkaesque at the best of times, particularly when you're hiring an outside firm to conduct the process. But Constantine Pappas, writing for e-discovery provider Relativity, offers up a list of questions inside counsel should be asking their outside counterparts to clarify the e-discovery process.

“It's critical to open the lines of communication early on, and keep them open at all times,” he says. Among the questions counsel need to ask are:

• What technology are you using? Not all lawyers have a detailed understanding of technology. Indeed, that could be the impetus for hiring outside counsel in the first place. But it's still necessary to understand why a particular platform was chosen. It's also critical to ask how much experience the lawyers have using that technology, and why it was selected for the specific case.
• How often can we expect updates on the case? Set the tone and the time line at the start of the project. Whether you want daily updates or more detailed metrics at specific checkpoints, ensure outside counsel know your expectations, says Pappas.
• How is this project being staffed? “Not all review teams are created alike. Some firms have their own dedicated review team, and others use staffing agencies they know and trust,” explains Pappas. To ensure you're satisfied with—and not surprised by—the team assigned to your case, ask for input in the selection process.