Form · Arbitration & Alternative Dispute Resolution
Redfern schedule for document production requests (with guidance)
An original Redfern schedule template for document requests in arbitration, with guidance on writing narrow and specific requests, objections and replies, columns for electronic search parameters, and a status tracker after the tribunal rules.
- Kind
- Form. A form to complete, or a guide to completing an official one.
- Where it applies
- Australia, International / cross-border
- AI use
- Yellow AI can help in set ways. A lawyer checks specific points before use.
- Law stated as at
- 17 October 2026
- Status
- Maintained. Checked on 17 October 2026 against the 3 authorities it cites, for Australia and International / cross-border.
- Version
- 1
- Source
- Written for this library
When to use it
Use when the tribunal's procedural order provides for document production by requests and objections, whether or not the IBA Rules on the Taking of Evidence are adopted as guidance. Not suited to court discovery, which follows the court's rules and orders.
How AI may be used
AI may populate the schedule from the parties' request and objection letters and track status, but whether a request is relevant and material, and whether an objection such as privilege is sound, are judgments for the lawyer.
AI may
- Transfer requests, objections and replies from correspondence into the schedule, keeping each party's wording
- Cross-refer each request to the pleading or submission paragraphs it relies on
- Track production status against the tribunal's decisions and flag overdue items
AI must not
- Must not decide or draft privilege objections without lawyer review
- Must not rewrite the other party's requests or objections when transferring them
- Must not be given the other party's produced documents in a tool that does not keep them confidential
The lawyer checks
- Each request is narrow, specific and tied to a pleaded issue
- Objections are justified and privilege claims are reviewed document by document
- The schedule follows the format in the procedural order
- Tribunal decisions are transcribed accurately into the status column
Method: how the Green, Yellow and Red levels are decided. This is guidance for planning, not legal advice.
Read the full text
The full text is for signed-in accounts. It is free. When you sign in you can:
- read the whole precedent, with its drafting notes beside it;
- copy it, or download it as a Word file or Markdown;
- add it to your firm’s knowledge base, so colleagues can find it;
- let the AI tools you connect read it from that knowledge base.
The summary, the law it rests on and the AI-use guidance above stay public. Privacy.
More in Arbitration & Alternative Dispute Resolution
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- Notice of arbitration (ACICA Rules, with UNCITRAL and ad hoc variants)
- Mediation agreement (with confidentiality and recording/AI-notetaker clause)
- Procedural order (or party agreement) on the use of AI in the arbitration
- Notice and consent for AI transcription or notetaking in mediations and other ADR sessions
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