Employment Arbitration Discovery Help

I’m preparing a dispositive motion in an ongoing employment arbitration and need a sharp hand to finish the discovery phase. My priority right now is gathering and organizing documentary evidence—specifically:

• Executed and draft employment agreements or side letters
• All performance reviews for the period in dispute
• Internal communications (memos, emails, chat logs) that touch on performance, discipline, or policy application

I’ll supply a custodian list, search terms, and the existing request set. Your job is to work through HR, IT, and our cloud repositories (OneDrive/SharePoint) to pull every responsive record, preserve original metadata, and apply sequential Bates numbers I provide. An indexed, chronologically ordered PDF set is the main deliverable; an Excel or Relativity-ready load file should accompany it so I can immediately slot the material into my motion practice.

Key acceptance criteria
• Complete document set delivered within 10 days, first-pass index in 5
• Metadata intact and privilege-flagged files clearly marked
• Consistent Bates numbering that matches my template
• Clear call-outs (highlight or annotation) on records that bolster affirmative defenses

If you already work in Relativity, Everlaw, Concordance, or similar e-discovery tools, all the better—let me know which. Timing is tight, so please share relevant experience with employment matters and confirm your availability this month.