---
title: "List the points to agree before electronic documents are exchanged in bulk"
url: "https://ailawframework.com/obligations/incoming-evidence-deepfakes-and-synthetic-documents/list-the-points-to-agree-before-electronic-documents-are-exchanged-in-bu"
type: "task"
site: "AI Law Framework"
id: "A44-FL20261022-12"
practice_area: "Incoming evidence — deepfakes & synthetic documents"
tier: "yellow"
lawyer_review: "required"
last_reviewed: "2026-10-22"
---

# List the points to agree before electronic documents are exchanged in bulk

> From the lawyer's note of the dispute and the documents, make an agenda with a blank beside each point: the issues in dispute; the likely number, nature and significance of the documents;…

Canonical page: https://ailawframework.com/obligations/incoming-evidence-deepfakes-and-synthetic-documents/list-the-points-to-agree-before-electronic-documents-are-exchanged-in-bu  
Last reviewed: 2026-10-22

Site index for agents: https://ailawframework.com/llms.txt

## Key facts

| Fact | Value |
| --- | --- |
| Practice area | [Incoming evidence — deepfakes & synthetic documents](https://ailawframework.com/obligations/incoming-evidence-deepfakes-and-synthetic-documents.md) |
| Human involvement | Yellow: Lawyer and AI draft together |
| How AI is used | From the lawyer's note of the dispute and the documents, make an agenda with a blank beside each point: the issues in dispute; the likely number, nature and significance of the documents; document descriptions for any list of documents; document structure, format and page numbering; the exchange medium; data security; how errors in exchanged documents will be managed; redaction of privileged or confidential documents; and the review methods named for discussion, being keyword searches, predictive code, de-duplication of documents and email threading. Copy a point only where the file already states it. Do not mark any point as agreed, and do not say that a protocol has been accepted. |
| What the lawyer must review | Where the proceeding is in the Federal Court of Australia, the lawyer checks the agenda against General Practice Note GPN-TECH, paragraphs 3.3 to 3.11, before anyone tells the Court that a protocol is agreed. The note expects the parties, before the Court considers an order for electronic discovery, to have discussed a practical and cost-effective discovery plan and to have conferred on the protocols for exchanging documents in electronic form. The plan and protocol must be proportionate and must not be an unreasonable economic or administrative burden. The Court's template protocol may be customised. The note says an alternative protocol is not used unless the parties fully agree it and the Court accepts it. The note also points parties to the Central Practice Note and to Part 20 of the Federal Court Rules; those documents are not applied in this task. The note is not used as the rule of another court. |
| Written for / versions | 1 jurisdiction versions below |

## Checking plan

**Source-by-source verification**

Trace relied-on content to independent sources and check for relevant material the output has missed.

- What the AI does: From the lawyer's note of the dispute and the documents, make an agenda with a blank beside each point: the issues in dispute; the likely number, nature and significance of the documents; document descriptions for any list of documents; document structure, format and page numbering; the exchange medium; data security; how errors in exchanged documents will be managed; redaction of privileged or confidential documents; and the review methods named for discussion, being keyword searches, predictive code, de-duplication of documents and email threading. Copy a point only where the file already states it. Do not mark any point as agreed, and do not say that a protocol has been accepted.
- What the lawyer does: Where the proceeding is in the Federal Court of Australia, the lawyer checks the agenda against General Practice Note GPN-TECH, paragraphs 3.3 to 3.11, before anyone tells the Court that a protocol is agreed. The note expects the parties, before the Court considers an order for electronic discovery, to have discussed a practical and cost-effective discovery plan and to have conferred on the protocols for exchanging documents in electronic form. The plan and protocol must be proportionate and must not be an unreasonable economic or administrative burden. The Court's template protocol may be customised. The note says an alternative protocol is not used unless the parties fully agree it and the Court accepts it. The note also points parties to the Central Practice Note and to Part 20 of the Federal Court Rules; those documents are not applied in this task. The note is not used as the rule of another court.
- Who reviews: Responsible lawyer with competence in the matter
- Basis: Practical workflow informed by the linked primary sources; the traffic light and working checks are editorial guidance, not a court classification.
- Why: The level reflects what the work is, the consequence of an error, and how much of the output the lawyer must independently re-derive.

## Checks the lawyer makes

1. Use the review methods in the words of the practice note, including predictive code. Do not rename them.
2. Do not mark a protocol as agreed or as accepted.
3. Do not treat the note as the rule of a state or territory court.
4. Do not add a hash or a file-format rule. The note's paragraphs used here do not state one.

## Notes

- These are suggested working checks. Confirm the required checking with the responsible lawyer before work starts; the checking approach does not establish permission to use AI.

## Sources

- [Federal Court General Practice Note GPN-TECH, Technology and the Court](https://www.fedcourt.gov.au/law-and-practice/practice-documents/practice-notes/gpn-tech) (checked 2026-10-22)

## Jurisdiction versions

| Jurisdiction | Level |
| --- | --- |
| [United States](https://ailawframework.com/obligations/incoming-evidence-deepfakes-and-synthetic-documents/list-the-points-to-agree-before-electronic-documents-are-exchanged-in-bu/united-states.md) | Yellow |

*Practice guidance for planning and review. Confirm current primary sources and the requirements of the actual matter. This is general information, not legal advice.*