---
title: "Redfern schedule for document production requests (with guidance)"
url: "https://ailawframework.com/precedents/arbitration-and-alternative-dispute-resolution/redfern-schedule"
type: "precedent"
site: "AI Law Framework"
id: "a6-redfern-schedule"
area_id: "A6"
kind: "form"
ai_level: "yellow"
version: 1
law_stated_as_at: "2026-10-17"
---

# 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…

Canonical page: https://ailawframework.com/precedents/arbitration-and-alternative-dispute-resolution/redfern-schedule  
Law stated as at: 2026-10-17

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

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.

## Key facts

- Kind: Form. A form to complete, or a guide to completing an official one.
- Practice area: [Arbitration & Alternative Dispute Resolution](https://ailawframework.com/precedents/arbitration-and-alternative-dispute-resolution.md)
- Jurisdictions: Australia, International / cross-border
- AI level: Yellow. AI can help in set ways. A lawyer checks specific points before use.
- Law stated as at: 2026-10-17
- Status: Maintained. Checked on 2026-10-17 against the 3 authorities it cites, for Australia and International / cross-border.

## 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

## Authorities

- [International Arbitration Act 1974 (Cth) Sch 2 (UNCITRAL Model Law) art 19](https://www.legislation.gov.au/C2004A00192/latest/text)
- [Commercial Arbitration Act 2010 (NSW) s 19](https://legislation.nsw.gov.au/view/html/inforce/current/act-2010-061)
- [IBA Rules on the Taking of Evidence in International Arbitration (2020) arts 3.3 and 9.2 (where adopted)](https://www.ibanet.org/MediaHandler?id=def0807b-9fec-43ef-b624-f2cb2af7cf7b)

## Full text and drafting notes

The full text and the drafting notes are not part of this public page. Signed-in firm accounts can read them at https://ailawframework.com/precedents/arbitration-and-alternative-dispute-resolution/redfern-schedule and through the signed-in MCP connector https://ailawframework.com/mcp/firm.

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