Jaber v. BPI Sports LLC et al
STIPULATED ORDER RE: DISCOVERY OF ELECTRONICALLY STORED INFORMATION FOR STANDARD LITIGATION. Signed by Judge Maxine M. Chesney on 03/20/17. (mmclc2, COURT STAFF) (Filed on 3/20/2017)
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
NICHOLAS JABER on behalf of himself, all
others similarly situated, and the general
Case Number: 16-cv-05355-MMC
[MODEL]STIPULATED ORDER RE:
DISCOVERY OF ELECTRONICALLY
STORED INFORMATION FOR
BPI SPORTS,LLC,IMAGE SPORTS, LLC
and BE POWERFUL,LLC,
This Order will govern discovery of electronically stored information ("ESI")in this
case as a supplement to the Federal Rules of Civil Procedure, this Court's Guidelines for the
Discovery of Electronically Stored Information, and any other applicable orders and rules.
The parties are aware of the importance the Court places on cooperation and commit to
cooperate in good faith throughout the matter consistent with this Court's Guidelines for the
Discovery of ESI.
The parties agree that in responding to an initial Fed. R. Civ. P. 34 request, or earlier if
appropriate, they will meet and confer about methods to search ESI in order to identify ESI
that is subject to production in discovery and filter out ESI that is not subject to discovery.
4 PRODUCTION FORMATS
The parties agree to produce documents in ~ PDF, ❑TIFF,
native and/or ❑paper or
a combination thereof(check all that apply)] file formats. If particular documents warrant a
different format, the parties will cooperate to arrange for the mutually acceptable production of
such documents. The parties agree not to degrade the searchability of documents as part ofthe
document production process.
5 DOCUMENTS PROTECTED FROM DISCOVERY
a Pursuant to Fed. R. Evid. 502(d), the production of a privileged or work-product)
protected document, whether inadvertent or otherwise, is not a waiver of privilege
or protection from discovery in this case or in any other federal or state proceeding.
For example,the mere production of privileged or work-product-protected
documents in this case as part of a mass production is not itself a waiver in this case
or in any other federal or state proceeding.
b Communications involving trial counsel that post-date the filing of the complaint
need not be placed on a privilege log.
This Stipulated Order may be modified by a Stipulated Order of the parties or by the
Court for good cause shown.
IT IS SO STIPULATED,through Counsel of Record.
16 ~ Dated: March 16, 2017
Counsel for Plaintiff
Dated: ~ ~~~/~
Counsel for Defendants
IT IS ORDERED that the forgoing Agreement is approved.
22 ~ Dated: March 20, 2017
UNITED STATES DISTRICT/MAGISTRATE JUDGE
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