Watson et al v. Crumbl LLC et al

Filing 43

STIPULATION and ORDER re Discovery of Electronically Stored Information and Related Matters signed by Magistrate Judge Carolyn K. Delaney on 9/25/2024. (Mendez Licea, O)

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Erin J. Ruben
MILBERG COLEMAN BRYSON
PHILLIPS GROSSMAN LLP
900 W. Morgan St.
Raleigh, NC 27603
[phone] (phone)
865-522-0049 (fax)
[e-mail]
Attorneys for Plaintiffs and Putative Classes
Other Counsel on Signature Page
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA

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LISA WATSON and ANGELA KEERS,
individually and on behalf of all others
similarly situated,

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Case No.: 2:23-cv-01770-DJC-CKD

Plaintiffs,

Hon. Daniel J. Calabretta

v.
CRUMBL LLC, CRUMBL IP, LLC,
CRUMBL FRANCHISING, LLC, and
CRUMBL ENTERPRISES, LLC ,

STIPULATION AND [PROPOSED]
ORDER REGARDING DISCOVERY
OF ELECTRONICALLY STORED
INFORMATION AND RELATED
MATTERS

Defendants.

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Plaintiffs Lisa Watson and Angela Keers (collectively, “Plaintiffs”) and Defendants

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Crumbl LLC, Crumbl IP, LLC, Crumbl Franchising, LLC, and Crumbl Enterprises, LLC

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(collectively, “Defendants”) (together, the “parties”), by and through their undersigned

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counsel, hereby stipulate and agree to the following provisions regarding the discovery

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of electronically stored information (“ESI”) in this matter.

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STIPULATION AND [PROPOSED] ORDER REGARDING DISCOVERY OF
ELECTRONICALLY STORED INFORMATION AND RELATED MATTERS
CASE NO. 2:23-CV-01770-DJC-CKD

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A.

General Principles

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1.

All parties are under an obligation to take reasonable steps to comply with

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this Stipulation and [Proposed] Order Regarding the Discovery of ESI and Related

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Matters (“Order”). The parties are aware of the importance the Court places on

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cooperation and have agreed to cooperate in good faith in facilitating discovery in this

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matter.

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2.

The procedures and protocols set forth in this Order shall govern the

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production format of hard-copy documents and ESI in this action, to the extent available,

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reasonably accessible, and proportional to the needs of this action all as contemplated

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by the Federal Rules of Civil Procedure, see Fed. R. Civ. P. 26(b)(1). By stipulating to

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this Order, the parties do not waive any objections, privileges, or arguments against the

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production or disclosure of documents, ESI, and other information.

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3.

The parties will attempt to resolve, in person, in writing (including email),

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or by telephone, disputes regarding the issues set forth herein before filing a motion with

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the Court, or otherwise seeking relief. If the parties are unable to resolve the dispute after

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a good-faith effort, the parties may seek Court intervention in accordance with the Court’s

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procedures.

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B.

ESI Discovery Procedures

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1.

On-site inspection of electronic media. Such an inspection will not be

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allowed, absent a demonstration by the requesting party of specific need and good

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cause, or, as allowed by agreement of the parties.

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a. Search methodology. Prior to any production the parties agree to meet and

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confer to discuss: (i) the identity and role of custodians from which

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documents will be obtained for the production; (ii) the identity, scope and

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format of custodial and non-custodial sources from which documents will

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be considered for production; and (iii) search terms.

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STIPULATION AND [PROPOSED] ORDER REGARDING DISCOVERY OF
ELECTRONICALLY STORED INFORMATION AND RELATED MATTERS
CASE NO. 2:23-CV-01770-DJC-CKD

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b. Technology Assisted Review (“TAR”).

The parties acknowledge the

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potential benefits of using TAR technology and methodology in assisting

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in the identification of responsive documents, whether used in combination

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with search terms or otherwise. The parties shall negotiate and discuss

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the proper procedures to use in this matter, including TAR, to identify a

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proportionate and reasonable number of potentially responsive documents

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in connection with the parties’ productions.

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2.

Format.
a. General ESI Production Format.

All responsive ESI and hardcopy

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documents, except that ESI which is produced in native format pursuant to

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Section 3(f), shall be produced as black and white, single-page, 300 DPI,

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Group IV TIFF files or in other reasonably viewable format. To the extent

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practicable, TIFF files should be assigned a unique name matching the

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Bates number of the corresponding image. To the extent practicable, Bates

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numbers and confidentiality designations should be electronically branded

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on each produced TIFF image. These TIFF images should be provided in

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folders limited to 1,000 files per folder. Where images are provided as

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single page TIFF images, a cross reference file (such as an OPT image

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load file) will be provided to delineate images by document. Documents

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shall be processed to reveal track changes, comments, and hidden content

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in Word documents and speaker notes and hidden content in presentation

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files.

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b. Physical Documents Production Format.

In scanning hardcopy

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documents, distinct documents should not be merged into a single record,

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and single documents should not be split into multiple records (i.e., paper

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documents should be logically grouped). If documents were scanned

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STIPULATION AND [PROPOSED] ORDER REGARDING DISCOVERY OF
ELECTRONICALLY STORED INFORMATION AND RELATED MATTERS
CASE NO. 2:23-CV-01770-DJC-CKD

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before this case, however, and are not logically grouped, they may be

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produced in the format in which they were maintained. In the case of an

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organized compilation of separate documents (for example, a binder

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containing several separate documents behind numbered tabs), the

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document behind each tab should be scanned separately. The parties will

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make reasonable efforts to group the documents correctly and to correct

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any grouping failures.

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c. Color. Documents containing color may, but need not, be produced in

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single-page color JPEG format. If an original document contains color

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necessary to understand the meaning or content of the document, the

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producing party shall product a color image and/or native file of the

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document. Content produced from any website or mobile application shall

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always be produced in a color image/or native file. Reasonable requests

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for color productions shall be honored.

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d. Extracted Text. To the extent reasonably possible, extracted text shall be

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produced from documents that are not redacted. The extracted text shall

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be in separate document-level UTF-8 TXT files provided in a separate

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folder. The number of TXT files per folder should be limited to 1,000 files.

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e. Native Production. Unless otherwise agreed to by the parties, the following

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four file types that are not easily converted to image format will be produced

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in native format unless they require redaction: (i) spreadsheet-type files

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(e.g. Microsoft Excel, Corel Quattro, etc.); (ii) presentation (e.g. Microsoft

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PowerPoint) and drawing files; (iii)

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database files (e.g. Microsoft Access).

audio/visual/multimedia; and (iv)

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f. Bates Numbering. Each document image file will be named with a unique

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number (Bates Number). When a text-searchable image file is produced,

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STIPULATION AND [PROPOSED] ORDER REGARDING DISCOVERY OF
ELECTRONICALLY STORED INFORMATION AND RELATED MATTERS
CASE NO. 2:23-CV-01770-DJC-CKD

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the producing party must preserve the integrity of the underlying ESI, i.e.,

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the original formatting, the metadata (as noted below) and, where

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applicable, the revision history. Any Bates numbering should be consistent

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across the production, contain no special characters, and be numerically

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sequential within a given document. If a Bates number or set of Bates

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numbers is skipped, the skipped number, or set of numbers, should be

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noted with a placeholder. Any attachments to documents assigned Bates

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numbers shall be assigned Bates numbers that directly follow the Bates

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numbers on the documents to which they were attached.

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g. Unitization. If a document is more than one page, the unitization of the

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document and any attachments and/or affixed notes will be maintained as

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they existed in the original document. The producing party will produce full

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families (parent documents and any attachments) for any non-privileged

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document(s) that hits on one or more of the applicable search terms,

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regardless of whether the document that hits on the search term(s) is the

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parent document or an attachment to the parent document.

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h. Parent-Child Relationships. The parties agree that if any part of an email

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or its attachments is responsive, the entire email and attachments will be

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produced, except that attachments may be withheld or redacted on the

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basis of privilege (including attorney/client, work product doctrine, or any

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recognized privilege) and/or non-responsiveness, and the relationship

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between attachments, enclosures, embedded files, and/or exhibits to any

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parent document shall be preserved. The child document should be

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consecutively produced immediately after the parent document. Each

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document shall be produced with the production number for the first and

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last page of that document in the “BEGDOC” and “ENDDOC” fields of the

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STIPULATION AND [PROPOSED] ORDER REGARDING DISCOVERY OF
ELECTRONICALLY STORED INFORMATION AND RELATED MATTERS
CASE NO. 2:23-CV-01770-DJC-CKD

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data load file and with the “BEGATTACH” and “ENDATTACH” fields listing

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the production number for the first and last page in the document family. If

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an attachment is withheld on the basis of privilege and/or non-

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responsiveness, the producing party will produce a placeholder (a single-

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page TIFF slip sheet) indicating that the attachment was withheld on the

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basis of attorney/client, work product doctrine, or any recognized privilege,

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and/or non-responsiveness.

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hyperlinks to the extent that they (a) are in the possession, custody or

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control of the producing party, and (b) can reliably, reasonably, and

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proportionately be identified and produced.
i.

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Attachments will include files sent via

Date and Time Fields. The Date and Time shall be produced in two
separate fields – Format: "12/24/2015” and “11:59 PM".

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Time Zone: When processing ESI, Coordinated Universal Time (UTC)
shall be selected as the time zone.

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k. Production Media. The preferred means of producing documents is via

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secure FTP or secure file share. However, due to large file size or other

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considerations, documents may also be produced via hard drive. Physical

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media should be password-protected before it is produced and delivered

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by separate means to the intended recipient.

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l.

Replacement Productions. Any replacement production will be transmitted

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with a cover letter or email to identify the production as a replacement and

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cross-reference the BegBates and EndBates of the documents being

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replaced. If the replacement production is being transmitted by physical

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media, the media shall include the phrase “Replacement Production.”

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m. Track Changes, Comments, and Similar Data. To the extent that a

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document or ESI contains tracked changes or comments, the document or

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STIPULATION AND [PROPOSED] ORDER REGARDING DISCOVERY OF
ELECTRONICALLY STORED INFORMATION AND RELATED MATTERS
CASE NO. 2:23-CV-01770-DJC-CKD

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ESI should be imaged showing tracked changes and comments, except

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where redacted for privilege. The tracked changes and comments shall

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also be produced in the accompanying text file.

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processed to TIFF format for purposes of applying redactions, shall be

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produced showing hidden slides and speakers’ notes, or if they contain

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non-privileged comments, may be produced in Native Format. Except in

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the case of a redaction, the hidden slides and speakers’ notes shall also

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be produced in the accompanying text file.

Presentation files, if

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n. Password-Protected or Encrypted Files. With respect to any ESI items that

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are password-protected or encrypted, the Producing Party will take

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reasonable and proportionate steps under the circumstances to break the

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protection or identify the password, if reasonably possible, so that the

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document can be reviewed and/or produced.

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o. System Files. Each Party will “de-NIST” system and application files,

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unless they are determined by the producing party to be responsive.
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De-duplication. The parties may de-duplicate their ESI production globally

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across custodial and non-custodial data sources. Removal of duplicate documents

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should only be done on exact duplicate documents (based on MD5 or SHA-1 hash

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values, at the family level). The initial custodian of a document and any subsequent

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custodians of deduplicated copies of the document should be listed in the “Custodians”

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field, with each custodian name separated by a semicolon. The parties also agree to

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track the file paths for the duplicate files and save and provide that file path data.

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5.

Email Threading. Each party, at its discretion, may use industry standard

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best practices and analytics technology to identify email threads and need only produce

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the unique most inclusive copy and related family members and may exclude lesser

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inclusive copies. With respect to an e-mail chain, the parties are permitted to produce

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STIPULATION AND [PROPOSED] ORDER REGARDING DISCOVERY OF
ELECTRONICALLY STORED INFORMATION AND RELATED MATTERS
CASE NO. 2:23-CV-01770-DJC-CKD

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the longest unique or most inclusive chain from lesser emails and the parties do not need

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to separately produce the lesser-included e-mails unless those lesser-included e-mails

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either (a) include unique attachments not included in the longest chain, or (b) contain a

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BCC recipient not shown in the longest unique chain. If a lesser-included e-mail includes

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a unique attachment, then the lesser-included e-mail must be separately produced with

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the attachment. A most inclusive email thread is one that contains all of the prior or

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lesser-inclusive emails, including attachments, for that branch of the email thread. Upon

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reasonable request, the producing party will produce a less inclusive copy.

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6.

Metadata fields. The parties agree that the metadata fields listed in

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Schedule A will be produced to the extent they are reasonably accessible and non-

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privileged.

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7.

Databases, Structured, Aggregated, or Application Data. If a database or

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other structured or aggregated data source contains responsive data, the parties shall

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meet and confer to address the most appropriate and cost-effective means for (a) the

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identification of responsive data fields, and (b) the production format, which may include

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running a report or a database export. The parties will reasonably cooperate in the

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exchange of information concerning such databases to facilitate discussions on

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identification and production format. Further, the parties will meet and confer regarding

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appropriate steps to be taken to protect the PII of any individuals which will be subject to

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production within the database.

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8.

Text Messages, Mobile Application Data and Collaboration Software

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Programs (Teams/Slack). If applicable sources exist in the possession, custody or

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control of a party, the parties will meet and confer to discuss the search parameters and

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format of production of these data types. The parties recognize that there is a wide

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variety of capabilities available, and it is difficult to assert a standard into a protocol

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without information as to each party’s capabilities.

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STIPULATION AND [PROPOSED] ORDER REGARDING DISCOVERY OF
ELECTRONICALLY STORED INFORMATION AND RELATED MATTERS
CASE NO. 2:23-CV-01770-DJC-CKD

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9.

Go Gets or Other Identifiable ESI or Documents. Nothing in Section C

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relieves a party of its obligations under the Federal Rules of Civil Procedure to search

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for and produce information and documents responsive to a discovery request

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propounded under those Rules, subject to valid objections pursuant to applicable law.

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D.

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The parties acknowledge that they have a common law obligation, as expressed

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in Rule 37(e) of the Federal Rule of Civil Procedure, to take reasonable and proportional

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steps to preserve discoverable information in the parties’ possession, custody, or control.

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With respect to preservation of ESI, the parties agree as follows:

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1.

Preservation of ESI

Absent a showing of good cause by the requesting party, the parties will

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not be required to modify the procedures used by them in the ordinary course of business

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to back-up and archive data; provided, however, that the parties will preserve all

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discoverable ESI in their possession, custody, or control.

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2.

The parties will supplement their disclosures in accordance with Rule 26(e)

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of the Federal Rules of Civil Procedure with discoverable ESI responsive to a particular

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discovery request or mandatory disclosure where that data is identified after a disclosure

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or response is made (unless excluded under Sections (D)(3) or (E)(1)-(2)). For clarity,

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the parties will not be required to log privileged or work product documents created after

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the filing of the complaint in this matter. Nothing in this Section relieves a party of its

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obligations under the Federal Rules of Civil Procedure to search for and produce

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information and documents responsive to a discovery request propounded under those

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Rules, subject to valid objections pursuant to applicable law.

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3.

Absent a showing of good cause by the requesting party, the following

categories of ESI need not be preserved or collected:
a. Deleted, slack, fragmented, or other data only accessible by forensics.

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STIPULATION AND [PROPOSED] ORDER REGARDING DISCOVERY OF
ELECTRONICALLY STORED INFORMATION AND RELATED MATTERS
CASE NO. 2:23-CV-01770-DJC-CKD

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b. Random access memory (RAM), temporary files, or other ephemeral data

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that are difficult to preserve without disabling the operating system.

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c. Online access data such as temporary internet files, history, cache,

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cookies, and the like.

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d. Data in metadata fields that are frequently updated automatically, such as

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last-opened dates.

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e. Back-up data that are duplicative of data that are more accessible

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elsewhere.

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f. Server, system, or network logs.

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g. Electronic data (e.g., email, calendars, contact data, and notes) sent to or

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from mobile devices (e.g., iPhone, iPad, Android devices), provided that a

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copy of all such electronic data is automatically saved in real time

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elsewhere (such as on a server, laptop, desktop computer, or “cloud”

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storage).

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E. Privilege
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Documents or information that are withheld from production, in whole or in

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part, on the basis of privilege must be disclosed on a privilege log in compliance with the

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requirements of Federal Rule of Civil Procedure 26(b)(5). The parties shall meet and

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confer in a good faith effort to reach agreement on the manner in which a privilege log

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will be generated and the contents of such a log, including: (a) other materials not

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required to be logged (in addition to those set forth in paragraph E.2); (b) requirements

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around the logging of email threads; (c) what metadata fields will be used to create the

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log; and (d) timing of the service of the logs after productions are made.

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2.

The parties are not required to log (a) privileged or work-product

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information generated after the filing of the complaint or (b) documents and records that

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have been redacted to remove PII.

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STIPULATION AND [PROPOSED] ORDER REGARDING DISCOVERY OF
ELECTRONICALLY STORED INFORMATION AND RELATED MATTERS
CASE NO. 2:23-CV-01770-DJC-CKD

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3.

Activities undertaken in compliance with the duty to preserve information

are protected from disclosure and discovery under Fed. R. Civ. P. 26(b)(3)(A) and (B).
4.

Pursuant to Fed. R. Evid. 502(d), the production of any documents in this

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matter will not, for the purposes of this proceeding or any other federal or state

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proceeding, constitute a waiver by the producing party of any privilege or protection

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applicable to those documents, including the attorney-client privilege, attorney work-

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product protection, or any other privilege or protection recognized by law. Information

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produced in discovery that is known or suspected to be protected as privileged or work

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product should be immediately returned to the producing party, and its production will

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not constitute a waiver of such protection.
5.

The production of any documents in this action will not constitute a waiver

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of any arguments by the producing party challenging the future admissibility or use of

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those documents in this matter.

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6.

Nothing contained in this Order is intended to or shall serve to limit a party’s

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right to conduct a review of documents, ESI or information (including metadata) for

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relevance, responsiveness and/or segregation of privileged and/or protected information

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before production.

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7.

In addition to the terms in this Section, the parties will comply with the terms

of the Stipulated Confidentiality and Protective Order.
F. Redactions

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A producing party may use redactions to protect any material that is legally

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privileged or is non-public personal information that the Producing Party contends does

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not need to be disclosed. 1 Any redactions shall be clearly indicated, including the grounds

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1 As used herein, “non-public personal information” (“NPPI”) includes individuals’
birthdates, Social Security numbers, taxpayer identification numbers, driver’s license
numbers, credit card numbers, financial account numbers, other financial information,
and the names and addresses of minors.
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STIPULATION AND [PROPOSED] ORDER REGARDING DISCOVERY OF
ELECTRONICALLY STORED INFORMATION AND RELATED MATTERS
CASE NO. 2:23-CV-01770-DJC-CKD

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for the redaction. Alternatively, a redaction log may be produced that identifies the

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document redacted and the grounds for the redaction. A Producing Party may not partially

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redact a document on the basis of relevance.

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1.

Spreadsheets.

Spreadsheets shall be redacted in native format using

eDiscovery industry best practices.
2.

Presentations.

Native presentations that require redactions shall be

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produced as TIFF images, which shall include speaker notes and “hidden” slides as

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extracted by the software used to process the documents. Color presentations requiring

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redactions shall be converted to color images, and black and white presentations

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requiring redactions shall be converted to black and white TIFF images, provided that

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proper grayscale printing is enabled to ensure that any dark colored text is not hidden by

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dark objects/drawings around the text. If the presentation contains video or audio

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components, the video or audio will be produced as native files with the appropriate

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attachment relationships.

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G. Third-Party ESI

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A party that issues a non-party subpoena shall include a copy of this Order with

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the subpoena and state that the parties to the litigation have requested that third parties

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produce documents in accordance with the specifications set forth herein. The party that

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issues a non-party subpoena is responsible for timely producing any documents obtained

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under a subpoena to all other parties.

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H. Amendment of Order

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Nothing herein shall preclude any party from seeking to amend this Order in writing

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for good cause shown, provided, however, that no party may seek relief from the Court

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STIPULATION AND [PROPOSED] ORDER REGARDING DISCOVERY OF
ELECTRONICALLY STORED INFORMATION AND RELATED MATTERS
CASE NO. 2:23-CV-01770-DJC-CKD

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concerning compliance with this Order until it has met and conferred in good faith with

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any parties involved in the dispute.

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I. Miscellaneous
Nothing herein constitutes an admission by any party that any particular category
of discovery is appropriate in this matter or that there exists producible ESI.

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IT IS SO ORDERED.
Dated: September 25, 2024
4, wats1770.23

_____________________________________
CAROLYN K. DELANEY
UNITED STATES MAGISTRATE JUDGE

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Submitted for Entry:
MILBERG COLEMAN BRYSON
PHILLIPS GROSSMAN LLP
/s/ Erin Ruben
Erin Ruben*
900 W. Morgan St.
Raleigh, NC 27603
T: 865-247-0080
F: 865-522-0049
[e-mail]
Harper T. Segui**
825 Lowcountry Blvd., Suite 101
Mount Pleasant, SC 29464
T: 919-600-5000

Foley & Lardner LLP
/s/ Jaikaran Singh
Jaikaran Singh, CA BAR NO. 201355
[e-mail]
11988 El Camino Real, Suite 400
San Diego, CA 92130
T: 858-847-6700
F: 858-792-6773
Jordan Bledsoe (Pro Hac Vice)
[e-mail]
Robert Stewart, CA BAR NO. 330308
[e-mail]
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STIPULATION AND [PROPOSED] ORDER REGARDING DISCOVERY OF
ELECTRONICALLY STORED INFORMATION AND RELATED MATTERS
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[e-mail]

2

Rachel Soffin*
800 S. Gay Street, Suite 1100
Knoxville, TN 37929
T: 865-247-0080
F: 865-522-0049
[e-mail]

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95 S. State Street, Suite 2500
Salt Lake City, UT 84111
T: 801.401.8900
F: 385-799-7576

*Admitted pro hac vice
**Motion to be admitted pro hac vice
forthcoming

Savannah Levin, CA BAR NO. 347929
[e-mail]
555 South Flower Street, Suite 3300
Los Angeles, CA 90071
T: 213-972-4500
F: 213-486-0065

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STIPULATION AND [PROPOSED] ORDER REGARDING DISCOVERY OF
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SCHEDULE A
Production Field Name

Relativity Field Name

BEGDOC

ProdBegBates

Beginning Bates number assigned to each document

ENDDOC

ProdEndBates

Ending Bates number assigned to each document

BEGATTACH

ProdBegAtt

Beginning Bates number assigned to the group of
documents to which the parent document and any
attachment documents are associated

ENDATTACH

ProdEndAtt

Ending Bates number assigned to the group of
documents to which the parent document and any
attachment documents are associated

CUSTODIANS

Dupe Custodian

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CONFIDENTIALITY

Production Branding

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RECORDTYPE

RecordType

The type of record (e.g., email, attachment, physical)

EMAILSUBJECT

EmailSubject

The subject line of a produced email

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DOCAUTHOR

DocAuthor

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TO

To

The “To” line of a produced email

CC

CC

The “CC” line of a produced email

BCC
PARENTDATE

BCC
ParentDate

The “BCC” line of a produced email
The date on which a document family’s parent was
sent, created, or modified.

PARENTTIME

ParentTime

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DATESENT

Sent Date

DATERECEIVED

Received Date

The time at which a document family’s parent was
sent, created, or modified. E.g. “22:08:23”
The date on which an email message was sent. E.g.:
"12/24/2015"
The date on which an email message was received.

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DATECREATED

Created Date

DATELASTMODIFIED

Last Modified Date

IMPORTANCE

Importance

FILENAME

FileName

NATIVEFILE

Prod NativeLink

TEXTFILE

Prod TextLink

FOLDER

Source Path

ALLFOLDER

DeDuped Paths

FILEEXTENSION

File Extension

3
4
5
6
7
8
9

14
15
16
17

20
21
22
23
24
25
26
27
28

Field Description

The custodian, (or multiple custodians for globally deduped documents) of a document
Confidential designation

The “From” line of a produced email or the Author of
a document

The date on which a file was created.
The date on which changes to a file were last saved.
Notation created for email messages to note a higher
level of importance than other email messages added
by the email originator.
The filename of a produced document
The location of the produced native version of a
document
The location of the extracted text/OCR text for a
document
File path/folder structure for the original native files as
it existed at the time of collection
File path/folder structure for the duplicate files as they
existed at the time of collection
Extension of original file

15

STIPULATION AND [PROPOSED] ORDER REGARDING DISCOVERY OF
ELECTRONICALLY STORED INFORMATION AND RELATED MATTERS
CASE NO. 2:23-CV-01770-DJC-CKD

FILEHASH

Hash

PRODVOLUME

Production Volume

SUSPECTOLE

Contains Embedded Files

4

COMMENTS

Comments

5

HASTRACKCHANGES

Track Changes

HIDDENTEXT

Has Hidden Data

FILESIZE

File Size

1
2
3

6

MD5 or SHA-1 Hash Value of document

7
8
9

PAGECOUNT
ATTACHMENTCOUNT

Number of Attachments

Volume number of production
The yes/no indicator of whether a file such as a
Microsoft Word document has additional files
embedded in it.
Comments extracted from the metadata of the native
file
The yes/no indicator of whether the track changes
metadata on an Office document is set to True.
Indication of the existence of hidden document data
such as hidden text in a Word document, hidden
columns, rows, or worksheets in Excel, or slide notes
in PowerPoint.
Generally a decimal number indicating the size in
bytes of a file.
Page count of produced images
Number of Attachments

REDACTED

Redacted

EMAILSUBJECT

Subject

The subject of the email message.

DOCUMENTTITLE

Document Title

The title of a non-email document.

12

DATESTARTED

Meeting Start Date

13

CONVERSATION

Conversation

CONVERSATIONINDEX

Conversation Index

10
11

Yes or No

The date on which a meeting item in Outlook
Normalized subject of email messages. This is the
subject line of the email after removing the RE and
FW that are added by the system when emails are
forwarded or replied to.
Email thread created by the email system. This is a
maximum 44-character string of numbers and letters
that is created in the initial email and has 10 characters
added for each reply or forward of an email.

14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

16

STIPULATION AND [PROPOSED] ORDER REGARDING DISCOVERY OF
ELECTRONICALLY STORED INFORMATION AND RELATED MATTERS
CASE NO. 2:23-CV-01770-DJC-CKD