Troudt et al v. Oracle Corporation et al

Filing 50

ORDER granting 47 Motion for Entry of Stipulation and Order for Discovery of Hard Copy Documents and Electronically Stored Information By Magistrate Judge Craig B. Shaffer on 4/29/2016.(cbslc1)

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Civil Action No. 1:16-cv-00175-REB-CBS
TROUDT, et al.,
Plaintiffs,
v.
ORACLE CORPORATION, et al.,
Defendants.
____________________________________________________________________________
ORDER REGARDING DISCOVERY OF HARD COPY DOCUMENTS AND
ELECTRONICALLY STORED INFORMATION
____________________________________________________________________________
Magistrate Judge Craig B. Shaffer
Upon the parties’ joint motion (Doc. 47), the court approves and adopts as an order of the court,
the parties’ attached Stipulation (originally filed at Doc. 47-1) for Discovery of Hard Copy
Documents and Electronically Stored Information.
So ORDERED.

Dated this 29th day of April 2016 in Denver, Colorado.

BY THE COURT
s/Craig B. Shaffer
U.S. Magistrate Judge

THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Civil Action No. 1:16-cv-00175-REB-CBS
DEBORAH TROUDT,
BRAD STAUF,
SUSAN CUTSFORTH,
WAYNE SELTZER,
MICHAEL HARKIN,
MIRIAM WAGNER, and
MICHAEL FOY,
individually and as representatives of a class of plan participants,
on behalf of the Oracle Corporation 401(k) Savings and Investment Plan
Plaintiffs,
v.
ORACLE CORPORATION,
ORACLE CORPORATION 401(K) COMMITTEE, and
JOHN DOES 1-20
Defendants.
STIPULATION AND ORDER FOR DISCOVERY OF HARD COPY DOCUMENTS
AND ELECTRONICALLY STORED INFORMATION
The Parties to the above-captioned action HEREBY STIPULATE AND AGREE,
by and through their undersigned counsel, that the following specifications shall govern
discovery of all documents, electronically stored information (“ESI”), and any other
materials and information produced by the Parties during discovery.
I.

General
A.

The Parties shall take reasonable steps to comply with the procedures set

forth in this Stipulation.

B.

To the extent reasonably possible, the production of documents shall be

conducted to maximize efficient and quick access to documents and minimize related
discovery costs. The terms of this Stipulation shall be construed so as to ensure the
prompt, efficient, and cost-effective exchange of information consistent with the Local
Rules, the Federal Rules of Civil Procedure, and any orders by this Court.
1.

Except as specifically limited herein, this Stipulation governs the

production of discoverable documents by the Parties during the litigation.
2.

This Stipulation shall not enlarge, reduce, or otherwise affect the

scope of discovery in this litigation as imposed by the Local Rules, the Federal Rules of
Civil Procedure, and the Court’s orders, nor imply that discovery produced under the
terms of this Stipulation is properly discoverable, relevant, or admissible in this or in any
other litigation.
3.

Subject to this Stipulation, the Parties’ objections and responses to

requests for production of documents and interrogatories, and the Agreed Protective
Order on Confidentiality to be later entered by the Court, all documents that are
responsive to discovery requests, are reasonably accessible, and that meet the
proportionality factors set forth in Fed. R. Civ. P. 26(b), shall be produced in the manner
provided herein. Nothing in this Stipulation and Order shall be interpreted to require
disclosure of materials that a Party contends are not discoverable or are protected from
disclosure by the attorney-client privilege, the work product doctrine, or any other
privilege that may be applicable. Additionally, nothing in this Stipulation and Order shall
be deemed to waive or limit any Party’s right to object to (and on that basis withhold) the

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production of documents or electronically stored information, or to seek relief from the
production of certain documents or electronically stored information, or to move for
protective order on the ground that the sources are not reasonably accessible because
of undue burden or cost, or move to compel on the ground that there is good cause for
the documents’ production.
4.

The Parties agree to promptly alert all other Parties concerning any

technical problems associated with complying with this Stipulation. To the extent the
Producing Party determine that compliance with this Stipulation imposes an undue
burden or is not proportional with respect to any protocol, source, or search term listed
herein, the Parties shall promptly confer in an effort to resolve the issue.
5.

Consistent with their obligations, the Parties will attempt to resolve,

in person, in writing (including e-mail), or by telephone, disputes regarding the issues
set forth herein prior to filing a motion with the Court, or otherwise seeking relief. If the
Parties are unable to resolve the dispute after a good faith effort, the Parties may seek
Court intervention in accordance with the Court’s procedures.
II.

Production Format – Hard Copy
Hard copy documents that have not been scanned by the Producing Party may

be produced as an exact hard copy, other than hard copy documents maintained at an
off-site location that will be separately negotiated by the Parties. At the Producing
Party’s election, or if hard copy documents have already been scanned by the
Producing Party, hard copy documents will be scanned and produced as either PDF or
single-page, black and white, Group IV, 300 DPI TIFF images with an .opt image cross-

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reference file and a delimited database load file (i.e., .dat). The database load file shall
contain the metadata fields listed in the attached Appendix A. The Parties will discuss
reasonable requests for production of color or oversized documents on a document-bydocument or category-by-category basis.
In scanning hard copy documents, multiple distinct documents should be
scanned as they are maintained and stored in the ordinary course. The Producing Party
shall provide OCR text for hard copy documents scanned for production. OCR is to be
performed on a document level and provided in document-level *.txt files named to
match the production number of the first page of the document to which the OCR text
corresponds. In the case of an organized compilation of separate documents –for
example, a binder containing several separate documents behind numbered tabs− the
document behind each tab should be scanned separately, but the relationship among
the documents in the binder should be reflected in the metadata fields.
III.

Production Format – Electronically Stored Information (“ESI”)
Except as otherwise noted herein or agreed on by the Parties, and

notwithstanding any format provisions in a Party’s discovery requests, ESI will generally
be produced in conformance with the specifications detailed in Appendix A. ESI shall be
produced in tiff + metadata format, except for Excel files, Word files, PowerPoint files,
and .pdf files, which shall be produced in native format, as specified in this Stipulation
and Appendix A. In addition, all ESI will be produced with a delimited database load file
containing the metadata fields listed in Appendix A and captured at the time of the
collection. Any Party, in addition to producing designated ESI in native format, may

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produce ESI in a TIFF + metadata format as specified in Appendix A. The Parties will
discuss reasonable requests for production of color or oversized documents on a
document-by-document or category-by-category basis. The parties agree to meet and
confer as to whether the Producing Party is required to produce files other than those
set forth in this paragraph in native format.
IV.

Production Format – Structured Data Sources
To the extent discoverable electronic information is contained in structured data

sources, the Parties will meet and confer to discuss the most appropriate and costeffective production format, which may include an export of data or the creation of a
report. There is no obligation for a Party to create reports in a format not already
available in the structured data source.
V.

Production Format - Media
Documents shall be exchanged on DVD-ROMs, CD-ROMs, USB drives, portable

hard drives, through secure file transfer protocols (e.g., SFTP), or similar secure
electronic transmission as agreed to by the Parties. The production media shall be
labeled with the Volume Number along with the Bates Number range(s) of the materials,
and where not practicable to do so, may be provided in an accompanying letter.
Any document production that may contain “non-public personal information” or
confidential health information (as defined in the Health Insurance Portability and
Accountability Act of 1996 (“HIPAA”) Privacy Rule and/or other applicable state or
federal law or regulation concerning confidential health information) shall be produced in
encrypted form and the production media shall be labeled “MAY CONTAIN NON-

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PUBLIC PERSONAL INFORMATION” or “MAY CONTAIN CONFIDENTIAL HEALTH
INFORMATION” as applicable.
If a Producing Party encrypts or “locks” the production, the Producing Party shall
simultaneously send, under separate cover, an explanation of how to decrypt the files.
VI.

Processing Specifications
A.

Redactions: With the exception of completely non-responsive documents

attached to an otherwise responsive document, no redactions will be made to
responsive documents except to redact privileged or otherwise protected information, or
personally identifiable information related to plan participants in the Oracle 401(k) Plan
Committee meeting minutes or related materials. However, the Producing Party must
ensure that any attached document not produced on the basis that it is completely, nonresponsive is identified to the Receiving Party. If, during the course of discovery, the
Parties identify other kinds of information that any Party has a reasonable basis for
redacting, the Parties will meet and confer before such redactions are made. If the issue
cannot be resolved, the Parties will seek resolution from the Court. In lieu of redacting
an entire document, the Producing Party may produce a slip-sheet for full documents
meeting the above redaction criteria.
B.

ESI Date and Time Processing: Each Party’s ESI should be processed

using a Coordinated Universal Time (or UTC) Time Zone for all data.
C.

Deduplication: A Party is only required to produce a single copy of a

responsive document and a Party may de-duplicate responsive ESI (based on MD5 or
SHA-1 hash values at the document level) across custodians. For e-mails with

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attachments, the hash value shall be generated based on the parent-child document
grouping. Deduplication shall not break apart families. However, metadata identifying all
custodians in possession of each document that is removed as a duplicate must be
produced in the “CUSTODIAN” or “DUPLICATE CUSTODIAN” or Duplicate Folder/Path
field in the production load file subject to any exceptions provided in Appendix A.
D.

Email Thread Suppression: The Parties agree to meet and confer to the

extent a party intends to use email thread suppression to exclude documents from
production. The producing party will disclose its intention to use thread suppression in
this manner prior to the applicable production deadline and with sufficient time to raise
the issue with the Court, if necessary.
VII.

Identification and Collection of Documents
A.

Except as otherwise agreed in this Stipulation, the Parties will continue to

meet and confer in an effort to agree (or reach impasse) upon the following by June 20,
2016, or as soon thereafter as practicable:
1.

List of key records custodians;

2.

Search methodology to be applied, including, but not limited to, any

search parameters, search terms, and date restrictions, if necessary;
3.

Location of relevant data sources including custodial and non-

custodial sources. This includes identifying both accessible and claimed inaccessible
sources, and, storage facilities.
B.

Search Methodology:
1.

Email and Non-Email: the parties agree to search for and produce

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responsive records from sources of hard copy and ESI to the extent such locations may
contain responsive information as outlined in Section VII.C.
2.

Determinations of discoverability and responsiveness shall be

made by the Producing Party.
C.

Location of Hard Copy and ESI: To the extent the following sources are

identified by the agreed-upon records custodians, or individuals identified by the
agreed-upon records custodian who have knowledge of the operation and
administration of the Plan, as containing potentially responsive data (hard copy or ESI),
and within the Producing Party’s possession, custody or control the Producing Party will
search the following sources to the extent they are reasonably accessible:
1.

Custodians’ hard copy files;

2.

Custodians’ local hard drives;

3.

Custodians’ mobile devices, to the extent such devices are within

the possession, custody, or control of the Producing Party;
4.

Custodian’s personal email accounts and computers;

5.

Custodians’ personal network drive;

6.

Custodians’ reasonably accessible corporate email accounts;

7.

A custodians’ removable or portable media (including, but not

limited to, thumb or flash drives, external hard drives, CDs or DVDs);
8.

Cloud drives or offsite electronic storage of documents;

9.

Hard copy documents stored offsite;

10.

Network drives or active server directories (i.e., shared drives);

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11.
12.

Shared email accounts; and

13.
VIII.

Databases;

Other sources later identified.

Preservation
A.

The Parties acknowledge that they have an obligation to take reasonable

and proportional steps to preserve discoverable information in the Party’s possession,
custody or control.
B.

The Parties agree that the circumstances of this case do not warrant the

preservation, collection, review, or production of ESI that is not reasonably accessible
because they anticipate that enough relevant information can be yielded from
reasonably accessible sources and, as necessary and appropriate, supplemented with
deposition discovery. Moreover, the remote possibility of additional relevant information
existing in not reasonably accessible sources is substantially outweighed by the burden
and cost of preservation, collection, review and production of ESI from sources that are
not reasonably accessible. The Parties agree that the following ESI is not reasonably
accessible:
1.

Data retained on back-up tapes.

2.

Deleted, shadowed, damaged, residual, slack, fragmented, or other

data only accessible by forensics.
3.

Random access memory (RAM), temporary files, or other

ephemeral data that are difficult to preserve without disabling the operating system.

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4.

On-line access data such as temporary Internet files, history,

cache, cookies, and the like.
5.

Data stored on photocopiers, scanners and fax machines.

6.

Data in metadata fields that are frequently updated automatically,

such as last-opened dates.
7.

Server, system or network logs.

8.

Electronic data (e.g., email, calendars, contact data, and notes) that

exist only on a mobile device (e.g., iPhone, iPad, Android, and Blackberry devices) that
is neither synched to nor retrievable from another source or device, provided that such
electronic data is routinely saved elsewhere (e.g., on a server, laptop, desktop
computer, or “cloud” storage) that the Producing Party believes, after necessary
interviews, does not contain relevant or responsive information.
C.

However, nothing herein shall prevent a Party from subsequently

requesting that ESI identified above be preserved and produced if specific facts
demonstrate a particular need for such evidence that justifies the burden of preservation
and retrieval. Further, nothing herein shall prevent a Party from requesting and
receiving additional detail and explanation from the Producing Party regarding any of
the above items that would allow the Requesting Party to further evaluate the substance
of the information and the burden and costs of retrieving and providing this information.
IX.

Privilege and Privilege Logs
A.

The Parties agree that (a) communications to or from Oracle’s

employees, agents, and representatives and from or to Oracle’s in-house or outside

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legal counsel relating to this litigation, (b) any work product of counsel and Parties
relating to this litigation, (c) any internal communications within a law firm relating to
this litigation, and (d) any communications regarding litigation holds or preservation,
collection, or review in direct connection with this lawsuit need not be included on a
privilege log.
B.

During the limited discovery period pending a ruling on Defendants’

motion to dismiss, the Parties agree that for documents redacted or withheld from
production on the basis of attorney-client privilege, work product doctrine and/or any
other applicable privilege, and not otherwise exempted under Section A or any Rules or
Local Rules, the Producing Party shall prepare a privilege log and provide a copy of
same, within 30 days after the 90-day production deadline set forth in the parties’
proposed joint scheduling order, in compliance with Fed.R.Civ.P. 26(b)(5). To the
extent any productions occur after the 90-day production deadline, the Producing Party
shall prepare a privilege log and provide a copy of the same within 21 days of the
corresponding production. To the extent the Producing Party concludes in good faith
that it will be unable to provide the privilege log within the applicable period set forth
above, it will promptly and in advance of the relevant deadline notify the Producing
Party so the Parties can meet and confer to determine the earliest practicable time the
privilege log(s) can be provided to the Requesting Party. The privilege log(s) described
above shall contain for each document claimed as privileged, the following information:
1. BEGNO
2. ENDNO

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3. ALL CUSTODIANS
4. DATE
5. AUTHOR
6. TO
7. CC
8. BCC
9. PRIVILEGE CLAIM ASSERTED (ATTORNEY-CLIENT PRIVILEGE
AND/OR WORK PRODUCT)
10. SUFFICIENT DESCRIPTION OF THE DOCUMENT OR
COMMUNICATION AT ISSUE THAT WILL ALLOW THE
RECEIVING PARTY AND THE COURT TO ASSESS THE CLAIM
OF PRIVILEGE
C.

In an effort to avoid unnecessary expense and burden, after the Court

rules on Defendants’ motion to dismiss, the parties agree to meet and confer as to
whether a Producing Party will be permitted to produce a summary log in lieu of a more
detailed privilege log as set forth in Sections IX(B) above or whether a more detailed
privilege log will be required throughout the remainder of the litigation.
X.

Third Party Documents
A Party that issues a non-Party subpoena (“Issuing Party”) shall include a copy of

this Stipulation with the subpoena and state that the Parties to the litigation have
requested that third parties produce documents in accordance with the specifications
set forth herein. However, third parties are not required to produce documents as

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specified herein. The Issuing Party shall produce any documents obtained pursuant to a
non-Party subpoena to the opposing Party. Nothing in this Stipulation is intended or
may be interpreted to narrow, expand, or otherwise affect the rights of the Parties or
third Parties to object to a subpoena.
XI.

Costs and Burden
The burdens placed on the Parties during this litigation, including during

discovery, must be proportional to the needs of the case. See Fed. R. Civ. P. 1; Fed. R.
Civ. P. 26(b)(1). All Parties reserve the right to seek shifting or sharing of certain
discovery costs, including vendor and attorneys’ fees, in appropriate circumstances.
XII.

Good Faith
The Parties shall make their best efforts to comply with and resolve any

differences concerning compliance with this Stipulation. If a Producing Party cannot
comply with any material aspect of this Stipulation, such Party shall inform the
Requesting Party as to why compliance with the Stipulation was unreasonable or not
possible within fifteen (15) days after so learning. No Party may seek relief from the
Court concerning compliance with the Stipulation unless it has conferred with other
affected Parties to the action.

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APPENDIX A TO STIPULATION AND ORDER FOR DISCOVERY OF HARD COPY
DOCUMENTS AND ELECTRONICALLY STORED INFORMATION
I.

Production Format
A.

Hard Copy Documents: Documents retained in hard copy form may be

produced as PDF or single page black and white, Group IV, 300 DPI TIFF images with
an .opt image cross-reference file and a delimited database load file (i.e., .dat) with
applicable objective coding fields listed below. The delimited database load file shall
include the page-document relationship and Bates number and page count and OCR’d
text, as well as any other information specified in Parts C and D below, and in the
manner specified in Parts C and D below (as applicable). If a produced TIFF image is
unreadable or appears to be otherwise missing information, the Requesting Party may
notify the Producing Party who will reproduce the document or portion of the document
if the original document is not similarly obscured. The Parties will discuss reasonable
requests for production of color or oversized documents on a document-by-document or
category-by-category basis.
B.

Electronically Stored Information (ESI): Except as otherwise noted in the

[Proposed] Stipulation and Order for Discovery of Hard Copy Documents and
Electronically Stored Information, herein or by agreement of the parties, ESI not
requiring redaction shall be produced in tiff + metadata format, except for Excel files,
Word files, PowerPoint files, and .pdf files, which shall be produced in native format. ESI
produced in tiff + metadata format will be produced as single-page, black and white,
Group IV, 300 DPI TIFF images with an .opt image cross-reference file and a delimited
database load file (i.e., .dat). ESI requiring redactions will be provided in the same
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format with OCR text performed after applicable redactions are applied to the produced
image. If appropriate, the Producing Party may redact Excel files natively as long as the
redacted text is clearly identified. The Parties will discuss reasonable requests for
production of color or oversized documents on a document-by-document or categoryby-category basis. The Parties agree to meet and confer as to whether the Producing
Party is required to produce files other than those set forth in this paragraph in native
format.
Native Files will be produced together with a relative file path to the Native File
provided in the metadata load file. The extractable metadata and text shall be produced
in the same manner as other documents that originated in electronic form to the extent
that metadata exists or is reasonably accessible or available for any files produced. If a
Producing Party wishes to designate a Native File “Confidential,” it shall do so by
producing the Native File on media that is labeled “Confidential” or by branding the
placeholder TIFF image “Confidential.”
C.

Bates Numbering: Each page of a tiff produced document will have a

legible, unique identifier (“Bates number”) assigned and electronically “burned” onto the
image. The identifier shall include an alpha prefix along with a fixed number, e.g.,
ABC000001. This format must remain consistent across all production numbers and be
placed on the lower right corner of all images so as not to unreasonably obliterate or
obscure any information. No other legend or stamp will be placed on a document image
other than confidentiality legends (where applicable) or redactions.

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D.

Associated Delimited Text File and Metadata Fields: A database load file

shall be provided in the Concordance “.dat” file format that holds metadata in fields as a
delimited text load file. For the load file, the Parties should use Concordance standard
delimiters (ASCII 020 corresponding to a comma, ASCII 254 corresponding to a double
quote, ASCII 174 corresponding to a new line, and a semicolon used to separate
values). To the extent captured at the time of the collection and processing, the fielded
data should include all the metadata fields listed below for a file/document in addition to
the unitization (including the production number of the first and last page of each
document) and attachments (including information sufficient to identify the parent and
child relationships of all documents that are or have attachments). The first line of the
data load file should contain the field headers indicating the contents of each field, and
each subsequent line should contain the fielded data for each document. Load files
shall include the metadata fields listed below, or substantially identical metadata fields,
to the extent already in existence and reasonably accessible. The Producing Party may
produce additional fields, but shall provide definitional information regarding such
field(s) values no later than the time of delivery of any production containing such fields.
To the extent that metadata does not exist or is not reasonably accessible or available
for any documents produced, nothing in this Stipulation shall require any Party to
extract, capture, collect generate or produce such data. However, the Parties will use
reasonable efforts to collect and process ESI in such a manner as to capture the
metadata fields required by this Stipulation.

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Hard Copy
FIELD NAME

FIELD DESCRIPTION

BEGBATES

Beginning production number or
Bates number for a given
file/document

ENDBATES

Ending production number or
Bates number for a given
file/document

BegAttach
EndAttach
PAGECOUNT

Number of pages for the
document

TEXT

Relative path to OCR text file

Confidentiality

Confidentiality Designation

Redaction

Redaction Reason

Custodian

Custodian or Source

ESI
FIELD NAME

SAMPLE DATA

FIELD DESCRIPTION

APPLICABLE
FILE TYPE(S)
E-mail and EDoc

BEGBATES

ABC000001

Beginning production
number or Bates number for
a given file/document

ENDBATES

ABC000002

Ending production number or E-mail and EBates number for a given
Doc
file/document

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FIELD NAME

FIELD DESCRIPTION

APPLICABLE
FILE TYPE(S)

ABC000001

Beginning production
number or Bates number for
the attachment range

E-mail and EDoc

ENDATTACH

ABC000015

Ending production number or E-mail and EBates number for the
Doc
attachment range

PARENT_BATES

ABC000001

BEGATTACH

SAMPLE DATA

First Bates number of parent
document/e-mail

E-mail and EDoc

**This PARENT_BATES field
should be populated in each
record representing an
attachment “child” document.
CHILD_BATES

ABC000002;
ABC000014

First Bates number of “child”
attachment(s); can be more
than one Bates number
listed depending on the
number of attachments
**The CHILD_BATES field
should be populated in each
record representing a
“parent” document.

E-mail and EDoc

CUSTODIAN

Smith, John

Person, shared file or other
source from whom files were
collected

E-mail and EDoc

DUPLICATE
CUSTODIAN

Brown
, Julie;
Black,
Joe

To identify other custodians
whose files contained a
particular document that was
eliminated through deduplication to the extent not
included in the CUSTODIAN
field

E-mail and EDoc

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FIELD NAME

SAMPLE DATA

FIELD DESCRIPTION

APPLICABLE
FILE TYPE(S)

DUPLICATE
PATH/FOLDER

\\serv
ernam
e\shar
e\Fold
er02

To identify other paths or
folder locations of files from
a particular document that
was eliminated through deduplication to the extent not
included in the PATH field.

E-Mail and EDoc

SUBJECT

Meeting Minutes

Subject line extracted from
e-mail message

E-mail

FROM

Thompson, Frank

Sender

E-mail

TO

Coffman, Janice;
Lee, William

Recipient

E-mail

CC

Cain, John

Copyee

E-mail

BCC

Stevens, Hunter

Blind Copyee

E-mail

DATESENT*

10/12/2012

Sent date of an email
message in the following
format:

E-mail

MM/DD/YYYY
TIMESENT*

07:05 PM

Time the email was sent,
with timezone normalized
across all produced records

E-mail

DATERCVD*

10/12/2012

Date an email message was
received in the following
format:

E-mail

MM/DD/YYYY
TIMERCVD*

07:05 PM

Time the email was received, E-mail
with timezone normalized
across all produced records

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FIELD NAME
AUTHOR*

SAMPLE DATA
Smith, John

FIELD DESCRIPTION
Name of person who created
document or email

APPLICABLE
FILE TYPE(S)
E-Doc

Parties acknowledge that the
Author field may not actually
be the Author of the
document.
FILENAME

October
Agenda.doc

Original file name of native
document

PATH

C:\My
Original path for documents
Documents\Agenda (if this information has been
captured)

E-mail and EDoc

DATECREATED*

10/1/2011

E-Doc

Date document was created
Parties acknowledge that the
Date Created field may not
actually be the Date Created
due to the ease of change to
that field and the technical
definition of the field (e.g.,
the created date reflects the
date when the file was
created in that particular
location on the computer or
on the other storage device
location)

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E-Doc

FIELD NAME
TIMECREATED*

SAMPLE DATA
9:18 AM

FIELD DESCRIPTION
Time document was created

APPLICABLE
FILE TYPE(S)
E-Doc

Parties acknowledge that the
Time Created field may not
actually be the Time Created
due to the ease of change to
that field and the technical
definition of the field (e.g.,
the created time reflects the
time when the file was
created in that particular
location on the computer or
on the other storage device
location)
DATELASTMOD*

10/15/2011

Date the document was last
modified in MM/DD/YYYY
format

E-Doc

TIMELASTMOD*

11:07 AM

Time file was last modified,
with timezone normalized
across all produced records

E-Doc

FILEEXT

Msg

File extension of native
document

E-mail and EDoc

PAGECOUNT

16

Number of pages for the
document

E-mail and EDoc

HASH

d131dd02c5e6eec5 MD5 or SHA1 Hash Value
694d0698aff85c2fs
ch5876217eab4004
5733b8fb789

E-mail and EDoc

NATIVEFILE
PATH

D:\001\ABC000005
.xls

Native

Original path or hyperlink to
documents being produced
in native file format

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FIELD NAME

SAMPLE DATA

FIELD DESCRIPTION

APPLICABLE
FILE TYPE(S)

TEXT

Relative path to
extracted text or
OCR for the
document

OCR or extracted text file

E-mail and EDoc

Redaction

Privilege

Reason for Redaction on a
Document

All

* As it relates to the date and time metadata fields included in the metadata fields
above, the Producing Party reserves the right to produce as a single field (e.g.
DATECREATED = DATECREATED + TIMECREATED) since the metadata may
already be exported and logged as such.

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