---
title: "Build an issue-to-document evidence table"
url: "https://ailawframework.com/practice/commercial-litigation-and-dispute-resolution/build-an-issue-to-document-evidence-table/united-states"
type: "task_jurisdiction_version"
site: "AI Law Framework"
id: "A5-P20260916-1-US"
practice_area: "Commercial Litigation & Dispute Resolution"
tier: "yellow"
lawyer_review: "required"
jurisdictions: ["US"]
last_reviewed: "2026-10-22"
---

# Build an issue-to-document evidence table

> For each issue the lawyer names, list the documents in the review set that mention it, with the page or control number. Do not describe a document that is not in the set.

Canonical page: https://ailawframework.com/practice/commercial-litigation-and-dispute-resolution/build-an-issue-to-document-evidence-table/united-states  
Last reviewed: 2026-10-22

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

## Key facts

| Fact | Value |
| --- | --- |
| Practice area | [Commercial Litigation & Dispute Resolution](https://ailawframework.com/practice/commercial-litigation-and-dispute-resolution.md) |
| Human involvement | Yellow: Lawyer and AI draft together |
| How AI is used | For each issue the lawyer names, list the documents in the review set that mention it, with the page or control number. Do not describe a document that is not in the set. |
| What the lawyer must review | Rule 26(b)(1) limits discovery to nonprivileged matter relevant to a claim or defense and proportional to the needs of the case. The table is a working paper for that scope. The lawyer checks each row against the document. Do not load produced discovery or work product into a public tool. Rule 1.6 and Formal Opinion 512 require the lawyer to protect confidentiality. A protective order may forbid tools that train on inputs. Read the order. |
| Written for | United States |
| Applies to | [Build an issue-to-document evidence table](https://ailawframework.com/practice/commercial-litigation-and-dispute-resolution/build-an-issue-to-document-evidence-table.md) |

## Checking plan

- What the AI does: For each issue the lawyer names, list the documents in the review set that mention it, with the page or control number. Do not describe a document that is not in the set.
- Basis: Checked against the linked sources on 22 October 2026. Confirm the current instrument before reliance.

## Notes

- Information need not be admissible to be discoverable. The table is not an evidence ruling.
- Privileged documents stay off a public model. A clawback under Rule 26(b)(5)(B) is the lawyer's notice, not the tool's.

## Sources

- [Federal Rule of Civil Procedure 26(b)(1) (scope of discovery)](https://www.law.cornell.edu/rules/frcp/rule_26) (checked 2026-10-22)
- [ABA Model Rule 1.6, Confidentiality of Information](https://www.americanbar.org/groups/professional_responsibility/publications/model_rules_of_professional_conduct/rule_1_6_confidentiality_of_information/) (checked 2026-10-22)
- [ABA Formal Opinion 512, Generative Artificial Intelligence Tools (29 July 2024)](https://www.americanbar.org/content/dam/aba/administrative/professional_responsibility/ethics-opinions/aba-formal-opinion-512.pdf) (checked 2026-10-22)

## Forms and precedents for this task

| Form or precedent | Kind | AI level | Summary |
| --- | --- | --- | --- |
| [Rule 26(f) discovery-plan report](https://ailawframework.com/precedents/commercial-litigation-and-dispute-resolution/us-rule-26f-discovery-plan.md) | Court document | Yellow | Joint report of the parties' Rule 26(f) conference for a United States district court, covering disclosures, phasing, ESI, privilege and the orders they will ask for under Rules 26(c) and 16(b). |
| [Deposition outline (not testimony)](https://ailawframework.com/precedents/commercial-litigation-and-dispute-resolution/us-deposition-outline.md) | Checklist | Yellow | Lawyer's outline of topics and questions for an oral deposition under Rule 30, including a Rule 30(b)(6) topic list. It is not a script of answers and it is not sworn evidence. |

Signed-in accounts can read the full text of each one.

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