Disclosures
Disclosure readiness, categories A through E
A — People likely to have discoverable information
12 of 14 have an address and a contact method · 13 have subjects recorded · 6 approved
| Name | Address | Telephone | Subjects of discoverable information | Category | Expected testimony | Approved | |
|---|---|---|---|---|---|---|---|
| Elena Ruiz | 1600 Wynkoop Street, Suite 400, Denver, CO, 80202 | elena.ruiz@meridian.demo | (303) 555-0119 | Repository access policy; the September 2, 2025 export | Both | 2 approved | Approved |
| Theo Marsh | c/o counsel for Plaintiff | c/o counsel | c/o counsel | Northstar and Calloway renewals | Both | 1 approved | Approved |
| Owen Castellano | Denver, CO | o.castellano@northstar.demo | (720) 555-0144 | Northstar’s renewal; the Cadence proposal | Potential trial witness | 1 draft | Pending |
| Former Halvorsen account executive Pseudonymize | Chicago, IL | Missing | Missing | How Tempo renewals were booked at Halvorsen in late 2025 | Discoverable information only | — | Pending |
| Grant Halvorsen | Missing | Missing | Missing | Halvorsen’s ownership and operating agreement | Not evaluated | — | Pending |
Categories A Through E.Complete, Missing, or Waiting on Counsel.
People and witnesses, documents and ESI, the damages computation, insurance and indemnity agreements, and the documents the pleadings refer to, each measured against what disclosure requires.
Disclosure readiness
- A — People and witnesses43%
12 of 14 have an address and a contact method · 13 have subjects recorded · 6 approved
- B — Documents, ESI and tangible things71%
29 of 41 documents have a privilege determination and have reached attorney approval or beyond
- C — Damages computation17%
1 of 6 damage items are approved and disclosure ready
- D — Insurance, indemnification and judgment agreements25%
1 of 4 entries located or ruled out
- E — Documents referred to in the pleadings75%
12 of 16 located, uploaded or determined not to exist
A — People.Every Name, Address and Subject, or Marked Missing.
Each person likely to have discoverable information, with their contact details, the subjects the record places them near, whether they may be called at trial, their expected testimony and counsel’s approval. A protected person appears under their description, not their name.
| Name | Address | Telephone | Subjects of discoverable information | Category | Expected testimony | Approved | |
|---|---|---|---|---|---|---|---|
| Elena Ruiz | 1600 Wynkoop Street, Suite 400, Denver, CO, 80202 | elena.ruiz@meridian.demo | (303) 555-0119 | Repository access policy; the September 2, 2025 export | Both | 2 approved | Approved |
| Theo Marsh | c/o counsel for Plaintiff | c/o counsel | c/o counsel | Northstar and Calloway renewals | Both | 1 approved | Approved |
| Owen Castellano | Denver, CO | o.castellano@northstar.demo | (720) 555-0144 | Northstar’s renewal; the Cadence proposal | Potential trial witness | 1 draft | Pending |
| Former Halvorsen account executive Pseudonymize | Chicago, IL | Missing | Missing | How Tempo renewals were booked at Halvorsen in late 2025 | Discoverable information only | — | Pending |
| Grant Halvorsen | Missing | Missing | Missing | Halvorsen’s ownership and operating agreement | Not evaluated | — | Pending |
D and E.Agreements and Referenced Documents, Tracked.
Every document the pleadings refer to is listed from the filed text, with whether it has been located, uploaded or reviewed and what to do next. Insurance and indemnity agreements are located, ruled out, or under attorney review.
E — Documents referred to in the pleadings
Generated from the filed text at ingestion, and added to by hand.
- Complaint ¶ 26Not located
Security alert record for the September 2, 2025 bulk download
Ruiz believes alert history is kept for 12 months, so it may have rolled off on September 2, 2026. Ask the security vendor whether a backup exists.
- Complaint ¶ 39Not located
Halvorsen invoices to Calloway, November–December 2025
Northstar produced its invoice. Calloway has not responded to its subpoena.
- Complaint ¶ 47Not located
Rennick bank records
Subpoena to Rennick’s bank not yet served.
- Complaint ¶ 18Located
Meridian conflict-of-interest policy acknowledged by directors
Client has the policy; signed acknowledgment pages not yet found.
- Complaint ¶ 28Uploaded
Rennick Slack export
- Complaint ¶ 24Reviewed
Repository access log for Halvorsen’s partner account
D — Insurance, indemnification and judgment agreements
- Halvorsen’s indemnity to Meridian under § 11 of the Reseller AgreementLocated
Covers third-party IP claims only. Does not reach Meridian’s own losses.
- Meridian D&O policy — any coverage for claims against a former directorAttorney reviewing
Exclusion 4(c) (insured v. insured) likely applies.
- Rennick’s errors-and-omissions or cyber policyNot located
Ask in Rennick interrogatories.
Build My Disclosures.Fifteen Steps to Served.
A step-by-step path from the first person reviewed to counsel’s approval, each step showing what is still outstanding, ending in a draft of the disclosures in Composer for counsel to review, sign and serve.
Nothing is exported without an attorney’s approval, and privileged material is excluded from every export.
← Initial disclosures
Build my disclosures
3 of 15 steps clear
- 1Review every person identified by the pleadings and evidence Clear
- 2Resolve initials and pseudonyms into actual identities2 outstanding
- 3Complete address, telephone and email2 outstanding
- 4Record the subjects of discoverable information1 outstanding
- 5Determine who may be called in the case-in-chief Clear
- 6Draft summaries of expected testimony Clear
- 7Attorney reviews and approves expected testimony3 outstanding
- 8Review documents and ESI that may be used in the case-in-chief12 outstanding
- 9Review damages computations and their supporting material5 outstanding
- 10Review insurance, indemnification and judgment agreements3 outstanding
- 11Locate every document referred to in the pleadings4 outstanding
- 12Run the privilege review2 outstanding
- 13Run the missing-data validation6 outstanding
- 14Attorney approval8 outstanding
- 15Draft the disclosuresDraft initial disclosures