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)

1 Galen D. Bellamy (SBN: 231792)
[e-mail]
2 Jacob A. Rey (pro hac vice)
[e-mail]
3 Jacob D. Taylor (pro hac vice)
[e-mail]
4 Wheeler Trigg O’Donnell LLP
370 Seventeenth Street, Suite 4500
5 Denver, CO 80202-5647
Telephone: [phone]
6 Facsimile: 303.244.1879
7 Dean J. Zipser (SBN: 94680)
[e-mail]
8 Adina W. Stowell (SBN: 211719)
[e-mail]
9 Umberg Zipser LLP
1920 Main Street, Suite 750
10 Irvine, CA 92614
Telephone: [phone]
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