---
title: "Check produced documents against a request to produce"
url: "https://ailawframework.com/practice/arbitration-and-alternative-dispute-resolution/check-produced-documents-against-a-request-to-produce"
type: "task"
site: "AI Law Framework"
id: "A6-OC20261022-2"
practice_area: "Arbitration & Alternative Dispute Resolution"
tier: "yellow"
lawyer_review: "required"
last_reviewed: "2026-10-22"
---

# Check produced documents against a request to produce

> Compare the documents produced with each request. List requests that are unanswered, objections that do not cite a ground in the rules, and requests that do not describe the documents, their relevance, or why the…

Canonical page: https://ailawframework.com/practice/arbitration-and-alternative-dispute-resolution/check-produced-documents-against-a-request-to-produce  
Last reviewed: 2026-10-22

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

## Key facts

| Fact | Value |
| --- | --- |
| Practice area | [Arbitration & Alternative Dispute Resolution](https://ailawframework.com/practice/arbitration-and-alternative-dispute-resolution.md) |
| Human involvement | Yellow: Lawyer and AI draft together |
| How AI is used | Compare the documents produced with each request. List requests that are unanswered, objections that do not cite a ground in the rules, and requests that do not describe the documents, their relevance, or why the requesting party does not have them. |
| What the lawyer must review | The lawyer decides which objections to maintain or challenge, and writes any submission to the tribunal. |
| 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: Compare the documents produced with each request. List requests that are unanswered, objections that do not cite a ground in the rules, and requests that do not describe the documents, their relevance, or why the requesting party does not have them.
- What the lawyer does: The lawyer decides which objections to maintain or challenge, and writes any submission to the tribunal.
- 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. Check each request for a description, relevance and materiality, and a statement that the documents are not in the requesting party possession or why production would be unreasonably burdensome.
2. Check that documents not objected to were produced within the time the tribunal ordered.
3. Limit objection grounds to Articles 9.2 or 9.3, or a failure to meet Article 3.3.
4. The lawyer writes any application for a ruling. The list itself is not filed as the submission.

## 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

- [IBA Rules on the Taking of Evidence in International Arbitration, adopted 17 December 2020](https://www.ibanet.org/MediaHandler?id=def0807b-9fec-43ef-b624-f2cb2af7cf7b) (checked 2026-10-22)

## Jurisdiction versions

| Jurisdiction | Level |
| --- | --- |
| [United States](https://ailawframework.com/practice/arbitration-and-alternative-dispute-resolution/check-produced-documents-against-a-request-to-produce/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.*