Coronis Health RCM LLC v. NextGen Laboratories, Inc

Filing 67

ORDER ON STIPULATED ORDER REGARDING DISCOVERY OF ELECTRONICALLY STORED INFORMATION by Magistrate Judge Douglas F. McCormick re Stipulation for Order 65 See document for details. (es)

Download PDF
1 Galen D. Bellamy (SBN: 231792) 2 Jacob A. Rey (pro hac vice) 3 Jacob D. Taylor (pro hac vice) 4 Wheeler Trigg O’Donnell LLP 370 Seventeenth Street, Suite 4500 5 Denver, CO 80202-5647 Telephone: 303.244.1800 6 Facsimile: 303.244.1879 7 Dean J. Zipser (SBN: 94680) 8 Adina W. Stowell (SBN: 211719) 9 Umberg Zipser LLP 1920 Main Street, Suite 750 10 Irvine, CA 92614 Telephone: 949.679.0052 11 Facsimile: 949.679.0461 12 Attorneys for Plaintiffs & Counter-Defendants Coronis Health RCM, LLC and Practical Holdings, 13 LLC 14 UNITED STATES DISTRICT COURT 15 CENTRAL DISTRICT OF CALIFORNIA 16 CORONIS HEALTH RCM, LLC; and 17 PRACTICAL HOLDINGS, LLC, F/K/A PRACTISOURCE, LLC, 18 Plaintiffs and Counter19 Defendants, 20 vs. 21 NEXTGEN LABORATORIES, INC, 22 23 24 25 Defendant and CounterClaimant. Case No.: 8:23-cv-00111-FWS-DFM Assigned to Hon. Fred W. Slaughter ORDER ON STIPULATED ORDER REGARDING DISCOVERY OF ELECTRONICALLY STORED INFORMATION Date Filed: December 2, 2022 Date Removed: January 18, 2023 Trial Date: Not set IT IS HEREBY STIPULATED AND AGREED by the parties, through their 26 respective counsel, subject to the approval of the Court, that the following Stipulated 27 Order Regarding the Discovery of Electronically Stored Information (the “Stipulated 28 ESI Protocol” or the “Protocol”) be entered by this Court: 1 CASE NO. 8:23-cv-00111-FWS-DFM STIPULATED ORDER REGARDING DISCOVERY OF ELECTRONICALLY STORED INFORMATION STIPULATED ESI PROTOCOL 1 2 1. Purpose 3 A. This Order will govern the discovery of electronically stored information 4 (“ESI”) as a supplement to the Federal Rules of Civil Procedure, this Court’s 5 Guidelines for the Discovery of Electronically Stored Information, and any other 6 applicable orders and rules. 7 2. Cooperation 8 A. The parties commit to cooperate in good faith throughout the matter. The 9 parties are expected to use reasonable, good-faith efforts to preserve, identify, and 10 produce relevant and discoverable information. This includes identifying custodians, 11 time periods for discovery, and keyword parameters to guide preservation and 12 discovery. 13 3. Non-Waiver. 14 A. To reduce the costs and burdens of discovery, the parties have entered 15 into a non-waiver agreement encompassing all elements and protections of Federal 16 Rule of Evidence 502(d), thereby reducing pre-production review costs and reducing 17 costly and costly time-consuming motions in the event of inadvertent production. 18 4. Proportionality 19 A. The parties will consider the proportionality standard set forth in Fed. R. 20 Civ. P. 26(b)(2)(C) in formulating their discovery plan. To further the application of 21 the proportionality standard in discovery, requests for production of ESI and related 22 responses should be reasonably targeted, clear, and as specific as practicable. The 23 parties will consider the option of prioritizing certain discovery where appropriate. 24 5. ESI Discovery Plan. 25 A. On or before May 22, 2023, or at a later time if agreed to by the Parties, 26 each Party shall designate and disclose to each other the following (the “Proposed ESI 27 Plans”): 28 2 STIPULATED ORDER REGARDING DISCOVERY OF ELECTRONICALLY STORED INFORMATION 1 i. Custodians. The name and title of each custodian the Party intends 2 to search for discoverable ESI, including (but not limited to) Email 3 communications. 4 ii. Non-custodial Data Sources. A list of non-custodial data sources 5 (e.g., shared drives, servers (including email servers such as 6 Exchange), document management systems, cloud-based folders, 7 databases, third-party data sources, etc.) the Party intends to search 8 for discoverable ESI. 9 iii. Search Terms. A list of the search terms, if any, that the Party 10 intends to apply to restrict or limit its review and/or production of 11 documents from each data source it identifies and which Requests 12 for Production each search term (or terms) corresponds. 13 iv. Search Term Hit Report. To facilitate agreement on search terms 14 and the resolution of disputes, the producing party shall timely 15 disclose hit reports for (1) its proposed search terms or 16 modifications and (2) terms or modifications proposed by the 17 requesting party. The hit report shall include the number of 18 documents that hit on each string, the number of unique documents 19 that hit on each string (documents that hit on a particular string and 20 no other string on the list), and the total number of documents that 21 would be returned by using the proposed search term list, both with 22 and without families. The hit reports shall be run after the 23 producing party globally de-duplicates documents. 24 v. Date Limitations. The date limitations, if any, the Party intends to 25 apply to restrict or limit its review and/or production of documents 26 from each data source it identifies, including identification of any 27 specific search terms or custodians that date limitations will 28 restrict. 3 STIPULATED ORDER REGARDING DISCOVERY OF ELECTRONICALLY STORED INFORMATION vi. 1 Technology Assisted Review (“TAR”). If a Party intends to use 2 TAR to assist any portion of its review process, it shall disclose its 3 proposed TAR protocols. vii. 4 Inaccessible Data. A list of all data sources, if any, that are 5 reasonably identifiable and likely to contain discoverable ESI (by 6 type, date, custodian, electronic system, or other criteria sufficient 7 to specifically identify the data source) that a Party asserts are not 8 reasonably accessible. 9 6. Duty of Producing Party 10 A. The Parties agree that if a producing Party is aware, or becomes aware, of 11 relevant or responsive ESI that was not extracted, identified, or produced under the 12 Party’s Proposed ESI Plan (e.g., the custodians identified or the search terms used did 13 not result in the identification or production of the ESI) the producing Party will 14 produce such ESI. 15 7. Preservation of ESI 16 A. The Parties acknowledge that they must take reasonable and proportional 17 steps to preserve discoverable information in the party’s possession, custody, or 18 control. 19 B. The parties agree that the circumstances of this case do not warrant the 20 preservation, collection, review, or production of ESI that is not reasonably accessible 21 because they anticipate that enough relevant information can be yielded from 22 reasonably accessible sources and, as necessary and appropriate, supplemented with 23 deposition discovery. Moreover, the remote possibility of additional relevant 24 information existing in not reasonably accessible sources is substantially outweighed 25 by the burden and cost of preservation, collection, review, and production of ESI from 26 sources that are not reasonably accessible. The parties agree that the following ESI is 27 not reasonably accessible: 28 4 STIPULATED ORDER REGARDING DISCOVERY OF ELECTRONICALLY STORED INFORMATION 1 i. Data maintained or duplicated in any electronic backup system for 2 system recovery or information restoration, including but not 3 limited to system recovery backup tapes or other media, continuity 4 of operations systems, and data or system mirrors or shadows, if 5 such data are routinely purged, overwritten or otherwise made not 6 reasonably accessible per an established routine system 7 maintenance policy. 8 ii. accessible by use of computer forensics; 9 10 iii. iv. Data relating to online access, such as temporary Internet files, browser history, file or memory caches, and cookies; 13 14 Random access memory (RAM), temporary files, or other ephemeral data that is difficult to preserve; 11 12 Unallocated, slack space, deleted data, file fragments, or other data v. Data in metadata fields that are frequently updated automatically 15 as part of the usual operation of a software application, operating 16 system, or network (e.g., data last opened) provided, however, that 17 such metadata as it exists at the time of preservation shall be 18 retained, produced, and not altered by the production process 19 unless it is separately preserved and produced with the relevant 20 document; 21 vi. saved, unless any such messages were otherwise stored or saved; 22 23 Telephone or VOIP voice messages that are not regularly stored or vii. Instant messages such as messages sent on Lync Online, Microsoft 24 Communicator, or any other instant message platform if not 25 maintained in the ordinary course of business. 26 viii. Data stored on cell phones or mobile devices, excluding tablets, 27 that is more reasonably accessible elsewhere, provided that the 28 alternative location is identified . The producing party shall 5 STIPULATED ORDER REGARDING DISCOVERY OF ELECTRONICALLY STORED INFORMATION 1 produce such data from reasonably accessible sources, along with 2 documentation of the specific device on which it is located. The 3 producing party shall do so without any additional request for 4 production from the receiving party. Further, all such devices that 5 were identified and that contain data that was not preserved shall 6 be identified; ix. 7 Call history records maintained on mobile devices, cell phones, or 8 Blackberries so long as copies of telephone bills that contain such 9 records are preserved and made available when responsive; x. 10 Operating system files, executable files, and log files (including 11 web server, web services, system, network, application log files, 12 and associated databases, analysis output caches, and archives of 13 such data), unless such log files may be used to identify putative 14 class members; and xi. 15 Other forms of ESI whose preservation requires extraordinary 16 affirmative measures that are not utilized in the ordinary course of 17 business. 18 C. Absent a showing of good cause, no party need restore any form of media 19 upon which backup data is maintained in a party’s normal or allowed processes, 20 including but not limited to backup tapes, disks, SAN, and other forms of media, to 21 comply with its discovery obligations in the present case. To avoid doubt, CDs, 22 DVDs, or other media used in the ordinary course of business to store original data 23 shall be searched for responsive material. 24 8. Sources of ESI 25 A. The parties agree to limit searches of discoverable ESI as follows. 26 Searches of ESI shall be limited to up to 6 custodians per party. Each party shall 27 designate its own custodians and, upon designation, disclose the identities of the 28 custodians to the other party. If a party requests ESI from more than 6 custodians, the 6 STIPULATED ORDER REGARDING DISCOVERY OF ELECTRONICALLY STORED INFORMATION 1 requesting party shall reimburse the producing party for the additional expenses of 2 searching for, collecting, reviewing, and producing any additional ESI. The time 3 period for ESI searches shall be limited to the time period of May 1, 2021, to January 4 18, 2023. 5 B. The parties further agree to be bound by the Stipulated Protective Order 6 during the sharing of ESI. Nothing in this Stipulated ESI Protocol precludes any party 7 from challenging the admissibility, discoverability, production, relevance, or 8 confidentiality of information produced under this Protocol or otherwise objecting to 9 its production or use at trial. 10 C. No party may seek relief from the Court concerning compliance with the 11 Protocol unless it has conferred with the party it believes to be in noncompliance with 12 the Protocol. 13 D. If necessary, the Stipulated ESI Protocol shall be amended by written 14 modification of all parties. 15 9. General Production Format 16 A. The parties will produce ESI in TIFF image format, with the exception of 17 documents that contain color images, which shall be produced in JPEG format, 18 provided that the documents do not become illegible or unusable or in any way alter 19 existing metadata when converted to TIFF image format. Any party may request 20 production of the native format of any document produced in any non-native format. 21 If a dispute arises regarding the reasonableness of the request, the parties agree to 22 meet and confer to resolve their differences. 23 B. Certain file types become illegible or unusable when converted to TIFF 24 image format (Microsoft Excel files, other similar spreadsheet application files, 25 Microsoft Project, and audio and video files), and these files must be produced in 26 native format unless they contain information that requires redaction. The parties 27 reserve their rights to seek additional electronic documents in their native format, 28 including natively redacted spreadsheet documents that preserve the searching, 7 STIPULATED ORDER REGARDING DISCOVERY OF ELECTRONICALLY STORED INFORMATION 1 sorting, and filtering characteristics intrinsic to spreadsheet functionality. Electronic 2 documents should be produced in such a fashion as to identify the location (i.e., the 3 network file folder, hard drive, backup tape, or other location) where the documents 4 are stored and, where applicable, the natural person in whose possession they were 5 found (or on whose hardware device they reside or are stored). 6 C. All production documents will be produced with extracted text and load 7 files, including the data fields provided in Exhibit A. In those instances where 8 redaction is used, OCR text will be provided instead of the extracted text to allow for 9 the removal of the redacted text from production. For documents produced in native 10 format, in addition to producing extracted text and the data fields in the table below, 11 the producing party will provide slip sheets endorsed with the production number and 12 level of confidentiality pursuant to any applicable protective orders in this case. 13 D. Non-electronic documents shall be scanned into a static-image format. 14 Copies of file folders and identification of file custodians shall be produced. 15 E. For documents that have originated in paper format, the following 16 specifications should be used for their production. 17 i. Each filename must be unique and match the Bates number of the 18 page. The filename should not contain any blank spaces and should 19 be zero-padded (for example, ABC00000001). 20 ii. Media may be delivered on CDs, DVDs, external USB hard drives, 21 or via secure FTP. Each media volume should have a unique name 22 and a consistent naming convention (for example, ZZZ001 or 23 SMITH001). 24 iii. file that contains document breaks. 25 26 Each delivery should be accompanied by an image cross-reference iv. Each metadata and coding field set forth below that can be 27 extracted shall be produced for each document. The parties are not 28 obligated to populate manually any of the fields below if such 8 STIPULATED ORDER REGARDING DISCOVERY OF ELECTRONICALLY STORED INFORMATION 1 fields cannot be extracted from a document, except the following: 2 (a) PRODBEG, (b) PRODEND, (c) BEGATT, (d) ENDATT, (e) 3 CUSTODIAN, (f) ALL CUSTODIAN, (g) NATIVEFILEPATH, 4 (h) TEXTFILEPATH, and (i) HASHVALUE, which should be 5 populated by the party or the party’s vendor. The parties will make 6 reasonable efforts to ensure that metadata fields automatically 7 extracted from the documents correspond directly to the 8 information that exists in the original documents. v. 9 The standard delimiters for the metadata load file should be: 10 Field Separator, ASCII character 020: “ ” 11 Quote Character, ASCII character 254 “þ” 12 Multi-Entry Delimiter, ASCII character 059: “;” 13 10. Image Format 14 A. Documents that are converted to TIFF image format will be produced in 15 accordance with the following technical specifications: 16 i. Images will be single-page, Group IV TIFF image files at 300 dpi; 17 ii. TIFF file names cannot contain embedded spaces; 18 iii. Bates numbers should be endorsed on the lower right corner of all 19 TIFF images and will be a unique, consistently formatted 20 identifier, i.e., alpha prefix, along with a fixed length number (e.g., 21 ABC0000001). The number of digits in the numeric portion of the 22 bates number format should not change in subsequent productions. iv. 23 left corner of all TIFF images; 24 25 26 27 28 Confidentiality designations, if any, will be endorsed on the lower B. Images will be delivered with an image load file in the Opticon (.OPT) file format. C. Images, native files, and text files should be stored and delivered in separate folders named “IMAGES,” “TEXT,” and “NATIVE.” Folders should be 9 STIPULATED ORDER REGARDING DISCOVERY OF ELECTRONICALLY STORED INFORMATION 1 segmented into directories, not to exceed 5,000 files. 2 11. Searchable Text 3 A. Searchable text of entire documents will be produced as an extracted text 4 for all documents originating in electronic format or, for any document from which 5 text cannot be extracted, as text generated using Optical Character Recognition (OCR) 6 technology. OCR text will be provided for all documents that originate from hard 7 copy or paper format. The full text of the redacted version of the document will be 8 produced for redacted documents. B. 9 Searchable text will be produced as a document-level multi-page ASCII 10 text file with the text file named the same as the PRODBEG field, placed in a separate 11 folder. The full path of the text file must be provided in the .DAT file for the TEXT 12 field. 13 12. Native Files 14 A. Native file documents, emails, or attachments may be included with the 15 electronic production using the below criteria: i. 16 Documents produced in native format shall be re-named to reflect the production number. 17 ii. 18 The full path of the native file must be provided in the .DAT file for the NATIVE FILE field; 19 iii. 20 The confidentiality designation under the Stipulated Protective 21 Order to be entered in this action will be produced in the load file 22 in the CONFIDENTIALITY field. 23 B. If documents produced in native format are printed for use in deposition, 24 motion, or hearing, the party printing the document must label the front page of the 25 file that is printed with the corresponding production number and, if applicable, the 26 confidentiality designation assigned by the producing party to that file under an 27 applicable protective order to be entered in this action. 28 C. Excel spreadsheets should be produced in native format with lock/protect 10 STIPULATED ORDER REGARDING DISCOVERY OF ELECTRONICALLY STORED INFORMATION 1 features and password protection disabled. 2 13. Embedded Objects 3 A. The parties may exclude embedded objects from the production. 4 B. Following the production of the files containing embedded objects, a 5 receiving party may make reasonable requests concerning specific embedded objects 6 particularly identified in the requests for the production of these embedded objects as 7 stand-alone files. The producing party shall cooperate reasonably in responding to any 8 such requests. 9 14. Structured Data 10 A. To the extent a response to discovery requires the production of 11 electronic information stored in a database, the parties will confer to attempt to agree 12 upon methods of production that will best provide all relevant information. 13 B. To determine the data that is relevant to the document requests, a list of 14 databases and systems used to manage potentially relevant data should be provided on 15 the date specified above with the following information. To the extent a database 16 contains both responsive and non-responsive information, only potentially responsive 17 information needs to be disclosed: Database Name Type of Database Software Platform Software Version Business Purpose A List of Standard Reports Database Owner or Administrator’s Name 18 19 20 21 22 23 24 C. The parties will consider whether all relevant information may be 25 provided by querying the database for discoverable information and generating a 26 report in a reasonably usable and exportable electronic file. If the parties agree to 27 production in this fashion, a document reference sheet shall be provided to describe 28 the purpose of the database and the meaning of all tables and column headers 11 STIPULATED ORDER REGARDING DISCOVERY OF ELECTRONICALLY STORED INFORMATION 1 contained in the report. 2 15. De-Duplication 3 A. Documents shall be de-duplicated across custodians before production. 4 The parties agree to use a verifiable de-duplication process to ensure that one copy of 5 a document is produced when feasible. A producing party shall identify all custodians 6 possessing de-duplicated documents in the “ALL CUSTODIAN” field, listed in 7 Exhibit A. 8 9 10 B. For the avoidance of doubt, a document is not considered to be a duplicate in the case where email headers or attachments differ in any regard or where the same document is both attached to an email and exists in a form that is separate 11 from such email (e.g., as an attachment to another email, as a standalone document 12 saved to some electronic media, etc.). 13 C. For good cause shown, the receiving party shall have the right to request 14 all duplicates of a produced document. 15 16. Email Threads 16 A. Email threads are email communications that contain prior or lesser- 17 inclusive email communications that also may exist separately in the party’s electronic 18 files. A most inclusive email thread is one that contains all of the prior or lesser19 inclusive emails, including attachments, for that branch of the email thread. 20 B. Each party may produce only the most inclusive email threads. 21 C. Similarly, a party may list the most inclusive email thread on any 22 required privilege log. However, if the most inclusive email thread contains privileged 23 portions and would otherwise be logged in its entirety as privileged, then the thread 24 must be produced with privileged material redacted and the redacted portion logged. 25 D. Following the production of the most-inclusive email threads, a receiving 26 party may make reasonable requests, concerning most-inclusive email threads 27 particularly identified in the requests, for the production of individual lesser-inclusive 28 emails. The producing party shall cooperate reasonably in responding to any such 12 STIPULATED ORDER REGARDING DISCOVERY OF ELECTRONICALLY STORED INFORMATION 1 requests. 2 17. Standard for Addressing Privilege 3 A. Under Fed. R. Evid. 502(d) and (e), the production of a privileged or 4 work-product-protected document, whether inadvertent or otherwise, is not a waiver 5 of privilege or protection from discovery in the pending case or any other federal or 6 state proceeding. Disclosures among defendants’ attorneys of work product or other 7 communications relating to issues of common interest shall not affect or be deemed a 8 waiver of any applicable privilege or protection from disclosure. For example, the 9 mere production of privileged or work-product-protected documents in this case as 10 part of mass production is not itself a waiver in this case or any other federal or state 11 proceeding. A producing party may assert privilege or protection over produced 12 documents at any time by notifying the receiving party in writing of the assertion of 13 privilege or protection. The receiving party must return, sequester, or destroy ESI that 14 the producing party claims is privileged or work product protected as provided in Rule 15 26(b)(5)(B) and may use such ESI only to challenge the claim of privilege or 16 protection. 17 B. Activities undertaken in compliance with the duty to preserve 18 information are protected from disclosure and discovery under Fed. R. Civ. P. 19 26(b)(3)(A) and (B). 20 C. Communications involving inside or outside counsel for the parties 21 related to this case that post-date the filing of the complaint need not be placed on a 22 privilege log. 23 D. The parties agree to furnish logs that comply with Fed. R. Civ. P. 24 26(b)(5) and any other legal requirements for all documents withheld or redacted on 25 the basis of privilege, attorney work product, or similar doctrines. Privilege logs may 26 be produced on a rolling basis or after all productions are complete but before the 27 close of discovery. 28 E. Nothing in this Order shall be interpreted to require disclosure of 13 STIPULATED ORDER REGARDING DISCOVERY OF ELECTRONICALLY STORED INFORMATION 1 irrelevant information or relevant information protected by the attorney-client 2 privilege, work-product doctrine, or any other applicable privilege or immunity. The 3 parties do not waive any objections to the production, discoverability, admissibility, or 4 confidentiality of documents and ESI. 5 18. Effect of Protocol and Reservation of Rights 6 A. The parties agree to be bound by this Order during the sharing of ESI. 7 Nothing in this Protocol precludes any party from challenging the admissibility, 8 discoverability, production, or confidentiality of information produced under this 9 Protocol or otherwise objecting to its production or use during the merits hearing or 10 11 12 during any other hearing. B. No party may seek relief from the Court concerning compliance with the Protocol unless it has first conferred with the other parties. 13 C. The Protocol may be amended by the written agreement of the parties. 14 D. Nothing in this Protocol shall be interpreted to require disclosure of 15 irrelevant information or relevant information protected by the attorney-client 16 privilege, work-product doctrine, or any other applicable privilege or immunity. 17 E. The parties shall confer on an appropriate non-waiver order pursuant to 18 Fed. R. Evid. 502. Until a non-waiver order is entered, information that contains 19 privileged matter or attorney work product shall be immediately returned to the 20 producing party (i) if such information appears on its face that it may have been 21 inadvertently produced or (ii) if the producing party provides notice within 15 days of 22 discovery by the producing party of the inadvertent production. 23 F. Nothing contained herein is intended to or shall serve to limit a party’s 24 right to conduct a review of documents, ESI, or information (including metadata) for 25 relevance, responsiveness, and/or segregation of privileged and/or protected 26 information before production. 27 28 14 STIPULATED ORDER REGARDING DISCOVERY OF ELECTRONICALLY STORED INFORMATION 1 Dated: May 19, 2023 2 3 IT IS SO ORDERED: 4 5 6 7 Hon. Douglas F. McCormick United States District Court 8 9 10 11 12 Dated: May 19, 2023 13 By: /s/Jacob A. Rey Galen D. Bellamy Jacob A. Rey (pro hac vice) Jacob D. Taylor (pro hac vice) 14 15 Attorneys for Plaintiffs & Counter-Defendants Coronis Health RCM, LLC and Practical Holdings, LLC 16 17 18 19 20 21 22 23 Dated: May 19, 2023 By: /s/ Seth B. Orkland Katie J. Brinson Seth B. Orkand (pro hac vice) Edward J. Heath (pro hac vice) Attorneys for Defendant & Counter-Claimant NextGen Laboratories, Inc. 24 25 26 27 28 15 STIPULATED ORDER REGARDING DISCOVERY OF ELECTRONICALLY STORED INFORMATION 1 EXHIBIT A 2 Field Definition 1 CUSTODIAN 10 2 PRODBEG 11 3 PRODEND 12 4 BEGATT 5 ENDATT 16 6 PGCOUNT 17 7 ATTACHCOUNT 18 8 FILENAME Name of person or data source from where documents/files are produced. Where redundant names occur, individuals should be distinguished by an initial which is kept constant throughout productions (e.g., Smith, John A. and Smith, John B.). Beginning Bates number (production number) Ending Bates number (production number) First Bates number of family range (i.e. Bates number of the first page of the parent email) Last Bates number of family range (i.e. Bates number of the last page of the last attachment) Number of pages in the document Number of attachments to an email Name of original file name of an E-Doc or attachment to an email 20 9 DOCEXT 21 10 MSGID 11 12 13 14 EMAILFROM EMAILTO EMAILCC EMAILBCC 15 16 EMAILSUBJECT DATE-TIME SENT (mm/dd/yyyy hh:mm:ss) 17 DATE-TIME RCVD Date and time received (mm/dd/yyyy hh:mm:ss) 3 4 5 6 7 8 9 13 14 15 19 22 23 24 25 26 27 28 File extension of the document Value extracted from parent message during processing Sender Recipient Additional recipients Blind additional recipients Subject line of email Date and time sent 1 EXHIBIT A Applicable Doc Type All All All All All All All E-docs All Email Email Email Email Email Email Email Email Field Definition 18 19 HASHVALUE TITLE 4 20 21 5 22 6 23 AUTHOR DATECRTD (mm/dd/yyyy) DATELASTMOD (mm/dd/yyyy) DOCTYPE MD5 Hash Value Title provided by user within the document Creator of a document Creation date 1 2 3 7 9 12 13 14 15 24 REDACTED 25 PRODVOL 26 CONFIDENTIALIT Y 27 TEXTPATH 28 NATIVEFILELINK 29 ALL CUSTODIAN 17 18 21 22 23 24 25 26 27 28 Edocs Descriptor of the type of document: All “E-attachments” for files that are attachments to emails; and 11 20 Last modified date “Emails” for all emails; 10 19 Edocs Edocs “E-document” for electronic documents not attached to emails; 8 16 Applicable Doc Type Email, Edocs Edocs “Paper” for hard copy physical documents that have been scanned and converted to an electronic image Descriptor for documents that have been redacted. “Yes” for redacted documents; “No” for unredacted documents. Name of media that data was produced on. Indicates if the document has been designated as “Confidential” or “Highly Confidential” pursuant to any applicable Protective Order. “No” indicates those documents that are not so designated. Full path for OCR or Extracted Text files on producing media Full path for documents provided in native format on producing media Name(s) of all custodian(s) that 2 EXHIBIT A All All All All Edocs Email 1 Field Definition FOLDERPATH possessed the document; includes any custodian(s) whose duplicate file(s) was removed during processing. File source path for all electronically collected documents and emails, which includes location, folder name and file extension. 2 3 4 5 6 7 8 30 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3 EXHIBIT A Applicable Doc Type Edocs  

Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.

Why Is My Information Online?