Jaber v. BPI Sports LLC et al

Filing 52


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1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 8 NICHOLAS JABER on behalf of himself, all others similarly situated, and the general public, 9 Plaintiff, 10 11 Case Number: 16-cv-05355-MMC [MODEL]STIPULATED ORDER RE: DISCOVERY OF ELECTRONICALLY STORED INFORMATION FOR STANDARD LITIGATION vs. 12 BPI SPORTS,LLC,IMAGE SPORTS, LLC and BE POWERFUL,LLC, 13 Defendants. 14 15 1. PURPOSE This Order will govern discovery of electronically stored information ("ESI")in this 16 case as a supplement to the Federal Rules of Civil Procedure, this Court's Guidelines for the 17 Discovery of Electronically Stored Information, and any other applicable orders and rules. 18 . 2 COOPERATION 19 The parties are aware of the importance the Court places on cooperation and commit to 0 2 cooperate in good faith throughout the matter consistent with this Court's Guidelines for the 21 Discovery of ESI. 22 . 3 SEARCH 23 24 25 6 2 27 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, 28 1 native and/or ❑paper or 1 2 3 4 5 6 7 8 9 10 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. 1 1 6 MODIFICATION . 12 This Stipulated Order may be modified by a Stipulated Order of the parties or by the 13 Court for good cause shown. 14 15 IT IS SO STIPULATED,through Counsel of Record. 16 ~ Dated: March 16, 2017 17 18 Counsel for Plaintiff Dated: ~ ~~~/~ 19 Counsel for Defendants 2 0 IT IS ORDERED that the forgoing Agreement is approved. 21 22 ~ Dated: March 20, 2017 23 UNITED STATES DISTRICT/MAGISTRATE JUDGE 24 25 26 27 28 2

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