DM Naming Convention

General Naming Conventions

All documents saved to DM must be coded using the proper and appropriate check boxes in the naming profile.

The Firm’s standard format for entering dates is “YYYY-MM-DD” (example: 2014-01-02). For documents filed with the court, the file stamp date is the date of the document. The Proof of Service date should be used if there is no file stamp. For correspondence, please use the date of the letter (as opposed to when the letter is received).

Case Law

[Case Name], [Cite], [Court, Year of Decision]

Example:

Johnson v. Higgins 283 F.Supp. 1223 (9th Cir., 2009)

Correspondence: Drafts

All letters in draft form should be saved with “DRAFT” in the document title so working copies are easily identified. The individual preferences of the partner will be deferred to when working with more than one version of a draft.

[DRAFT][Correspondence Type] to [Party]

Example:

DRAFT Meet and Confer Letter to Chiquita
DRAFT Letter to Susan Miller re tender response

Correspondence: Final

All final issued letters should be saved with “FINAL” at the end of the document title so that no changes can be made.

[Date][Correspondence Type] to [Party][FINAL]

Example:

2014-07-22 Litigation Hold to Allstate FINAL
2015-01-20 Letter to Harold Thomas FINAL

Correspondence: Received from Outside

When saving correspondence received from outside parties, please use the date the letter was written (as opposed to when the letter is received by our office).

[Date][Sending Party][Correspondence Type][Brief Description]

Example:

2013-06-18 Donaldson Response Letter
2014-04-20 Bob Smith Letter encl. Document Production BS0001-BS0503

Discovery Documents

[Date][Filing Party][Type of Discovery] to [Party] [(Set Number, If Applicable)]

Example:

2013-08-16 National Union Request for Documents to Chiquita
2014-06-11 Munich Re Request for Admission to Michael Johnson
2015-01-27 Swiss Re Request For Documents to Liberty Mutual (Set Two)

Draft discovery documents should be saved in the same manner as draft correspondence:

[DRAFT][Filing Party][Type of Discovery] to [Party] [(Set Number, if applicable)]

Example:

DRAFT National Union Requests for Admission to Chiquita (Set One)
DRAFT Endurance Special Interrogatories to VM Energy (Set Two)

Document Productions

[Bates Range](rec’d from [Party][Date])

Example:

ABC00500 – ABC01000 (rec’d from John Smith 2014-01-02)

Insurance Policies

[Insurer] [Policy Type] [Policy No.] (Effective Dates)

Example:

AISLIC Excess Policy No. 123456 (2014-01-01 to 2015-01-01)

Pleadings

[Date][Filing Party][Filing]

Examples:

2014-03-20 Halliburton Motion to Remand
2013-04-15 National Union’s Motion to Request Hearing

** Where applicable, the document or docket number entry of the filed document should be included in the document name (abbreviated as “ECF”).

[Date]{[Document/Docket Number, If Applicable]}[Filing Party][Filing]

Example:

2013-06-11 [ECF 120-1] Liberty Mutual Notice of Motion and Motion for Summary Judgment
2014-08-05 [ECF 80] National Union Motion to Dismiss

Draft pleadings should be saved in the same manner as draft correspondence.

[DRAFT][Filing Party][Filing]

Example:

DRAFT National Union Motion to Strike
DRAFT Thorpe Declaration iso Motion for Summary Judgment

Transcripts (Deposition, Trial, Hearing)

[Date] [Transcript Type/Description][(Condensed/Full)]

Examples:

2014-06-05 Deposition of Robert Smith (Full)
2010-08-29 Hearing Transcript re Zurich’s Motion to Dismiss (Condensed)

Work Product Memorandums

Work product documents should be named with a brief description of the issue or subject, and should remain undated until finalized. Once finalized, the date should appear at the beginning.

[Case Short Name] Memo re [Brief Description of Issue/Subject]

Example:

Chiquita Memo re Asbestos Exclusions in Texas Policies
2015-06-11 West Ocean Memo re Number of Occurrences