Doe (L.M.H.) v. Red Roof Inns, Inc. et al

Filing 34

Order issued governing discovery of ESI. Signed by Magistrate Judge Elizabeth Preston Deavers on 3/11/25. (sem)

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF OHIO
EASTERN DIVISION
Case Nos. 24-cv-00389; 24-cv-01823
IN RE: HOTEL TVPRA LITIGATION 1
Judge Algenon L. Marbley
Magistrate Judge Elizabeth A. Preston Deavers
ORDER GOVERNING DISCOVERY OF ESI
The parties to the above-captioned Action (the “Parties,” and each, a “Party”) stipulate and
agree that the following specifications shall govern discovery of all physical documents,
electronically stored information, and any other materials and information, if any, produced by the
parties during discovery in the above-captioned action.
I.

DEFINITIONS

The following definitions apply to this Order Regarding Discovery of Electronically Stored
Information (“ESI Order”).
1.

“Action” means the above-captioned matter.

2.

“Custodian” means the individual or originating source from which

Documents or ESI will be collected and reviewed.
3.

“Document” and “Electronically Stored Information” (“ESI”) is defined to

be synonymous in meaning and equal in scope to the usage of the term “documents or

1 For the convenience of the parties and for administrative purposes, the Court will

collectively refer to Case No. 2:19-cv-755 and all Related Cases as “In re Hotel TVPRA
Litigation.” The Clerk is DIRECTED to file this Notice in ONLY those cases identified in the
caption.
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electronically stored information” in Federal Rule 34(a)(1)(A). A draft or non-identical copy is a
separate document within the meaning of this term.
4.

“Native Format” means and refers to the file structure of a document created

by the original creating application (in contrast to a Static Image, which is a representation of ESI
produced by converting a native file into a standard image format capable of being viewed and
printed on standard computer systems, such as .tiff or .pdf).
5.

“Metadata” means (i) information associated with or about a file that is not

ordinarily viewable or printable from the application that generated, edited, or modified such
native file which describes the characteristics, origins, or usage or validity of the electronic file;
and (ii) information generated automatically by the operation of a computer or other information
technology system when a native file is created, modified, transmitted, deleted, saved, or otherwise
manipulated by a user of such system.
6.

“Load File” means an electronic file containing information identifying a

set of paper-scanned images or processed ESI and indicating where individual pages or files belong
together as documents, including attachments, and where each document begins and ends. A Load
File will also contain data relevant to the individual Documents, including extracted and usercreated Metadata, as well as OCR or Extracted Text, should such data be available.
7.

“OCR” means optical character recognition technology which is created by

software used in conjunction with a scanner that is capable of reading text-based paper/hard copy
documents and making such documents searchable using appropriate software.
8.

“Extracted Text” means the text extracted from a native document, and

includes all header, footer, and document body information, including any hidden content, when
available. A “Text File” is a file containing the full multi-page text of native or near-native files
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extracted directly from the native file, or, in the case of paper/hard copy documents subject to
OCR, a file containing the text resulting from the OCR.
9.

“Media” means an object or device, including but not limited to, a disc, tape,

computer, or other device, on which data is or was stored.
10.

“Parties” collectively shall mean all named parties to any action in these

Proceedings, including any Party added or joined to any complaint in these Proceedings, as well
as named parties to actions that may be consolidated into or coordinated with the above-captioned
Action.
11.

“Predictive Coding/Technology Assisted Review” shall mean processes for

prioritizing or coding a collection of documents using computerized systems, such as machinelearning algorithms, that may rely on the judgments of one or more attorneys experienced in the
subject matter of a litigation regarding the responsiveness of a subset of documents and
extrapolates those judgments to the remaining document collection. For purposes of this Protocol,
Predictive Coding/Technology Assisted Review is synonymous with computer-assisted review,
computer-aided review, and content-based advanced analytics or other terms used to refer to search
methodologies that rely on machine-based learning to identify responsive documents.
12.

“Production” or “Produced” includes any exchange of Documents or

Electronically Stored Information between the Parties, whether voluntarily or in response to a
formal or informal request.
13.

“Search Term” means a combination of words (including synonyms) and

phrases designed to capture potentially relevant ESI and includes strings of words and phrases
joined by proximity and Boolean connectors.
14.

“Search Criteria” includes date ranges and file types.
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15.

“Static Image” means or refers to a representation of ESI produced by

converting a native file into a standard image format capable of being viewed and printed on
standard computer systems. A Tagged Image File Format (TIFF) image is an example of a Static
Image. “TIFF” refers to the CCITT Group IV graphic file format for storing bit-mapped images of
ESI or paper Documents.
16.

“Structured Data” means ESI stored in a structured format, such as

databases or data sets according to specific form and content rules as defined by each field of the
database.
17.

“Unstructured Data” refers to free-form data which either does not have a

data structure or has a data structure not easily readable by a computer without the use of a specific
program designed to interpret the data, such as word processing documents, slide presentations,
Email, and image files.
II.

GENERAL
A.

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

out in this ESI Order. The Parties agree to promptly alert all other Parties concerning any technical
problems associated with complying with this ESI Order. If compliance with this ESI Order
imposes an undue burden with respect to any protocol, source, or search term listed herein, the
Parties shall promptly confer in good faith in an effort to resolve the issue.
B.

The purpose of this Order is to facilitate the exchange of physical

documents and ESI in an efficient manner and in accordance with the Federal Rules of Civil
Procedure (“Federal Rules”). By stipulating to this Order and agreeing to produce documents,
generally, in a particular form or form, except as specifically set forth herein, this Order does not:

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1.

Alter or affect the applicability of the Federal Rules or any Local
Rules of the U.S. District Courts (“Local Rules”), as applicable;

2.

Enlarge, reduce, or otherwise affect the scope of discovery in this
litigation as imposed by the Court’s orders;

3.

Address, limit, determine, or affect the relevance, discoverability, or
admissibility as evidence of any document or ESI, regardless of
whether the document or ESI is to be preserved, is preserved, or is
produced;

4.

Imply that discovery produced under the terms of this ESI ORDER
is properly relevant, discoverable, or admissible in this or in any
other litigation; or

5.

Alter or affect the objections of discovery applicable under the Federal
Rules, and no Party waives any objections to producing any particular
document or category of documents on any grounds whatsoever.

C.

If reasonably possible, the production of physical documents and ESI shall

be conducted to maximize efficient and quick access and minimize related discovery costs. The
terms of this ESI Order shall be construed to ensure the prompt, efficient, and cost-effective
exchange of information consistent with the Federal Rules, the Local Rules, and any orders that
have been entered by this Court in this case.
D.

All documents that are produced in this Action shall be produced in the

manner provided herein, provided however, that the Parties may agree to other forms of production
for all or part of the documents produced. Nothing in this ESI Order shall be interpreted to require
disclosure of physical documents, ESI or other materials that a Party contends are not discoverable
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or are protected from disclosure by the attorney-client privilege, the attorney work product doctrine,
or any other privilege that may be applicable. Additionally, nothing in this ESI Order shall be
deemed to waive or limit any Party’s right to object to the production of certain physical documents
or ESI, or to move for an appropriate order on the ground that the sources are not reasonably
accessible because of undue burden or cost or on the ground that there is no good cause for the
documents/production. Nothing in this ESI Order shall be deemed to limit, modify, or override
any provision of the confidentiality order entered in this case to govern production of confidential
information.
III.

IDENTIFICATION OF RESPONSIVE ESI

Consistent with their obligations under the applicable Federal Rules and Local Rules, the
Parties will attempt to resolve, in person, in writing (including email), or by telephone, disputes
regarding the issues set forth herein before 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.
IV.

PRODUCTION OF PHYSICAL DOCUMENTS AS STATIC IMAGES

Documents that exist solely in physical hard-copy format shall be scanned and produced in
color where the original hard-copy document exists in color and shall also be scanned and
produced as either (a) single-page, Group IV, 300 DPI TIFF images or (b) single-page JPEG
images, with an Opticon image Load File using ANSI/Western European encoding (“OPT file”)
and a delimited database Load File (“DAT file”). The DAT file should contain the fields listed in
Exhibit A. Hard copy documents should be physically unitized. The Parties reserve the right to
allocate costs of color scanning if it becomes burdensome, and any such requests are subject to the
boundaries of proportionality.
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If the producing party performs optical character recognition (“OCR”) on a document for
its own benefit, the document-level OCR text should be produced as an accompanying plain text
file named after the bates number in the “BEGNO” field of the DAT. To the extent OCR plain
text files are produced, the producing party is not certifying that the accompanying text file is
accurate or reliable for searching purposes beyond the application of the underlying OCR
technology.
V.

PRODUCTION FORMAT FOR ESI
A.

General: All ESI should be produced as single-page, Group IV, 300 DPI

TIFF in black and white.
B.

Native Production: The following file types shall be produced in native

format unless they are redacted in image format: (i) audio, (ii) video, (iii) databases, (iv)
spreadsheet-type files (e.g. Microsoft Excel, Corel Quattro, etc.), (v), computer slide presentations,
including PowerPoint, Google Slides, Keynote slides etc.; (vi) JPEGs; and (vii) multimedia files
(e.g. GIFs, animations or combination of text, sound and/or motion video). All native files shall be
processed to show and reveal all color, comments, revision marks, speaker notes, or other userentered data which are visible in any view of the document in its native application.
1.

Documents produced in native format should be named according
to the Bates number assigned, with the confidentiality designation
appended to the Bates numbers with a hyphen. Native documents
should be linked directly to their corresponding records in the DAT
file using the NATIVELINK field.

2.

Single-page Bates-stamped TIFF image slip-sheets will be included
for each document produced in native format. The slip-sheets will
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display the Bates number of the native file, the Confidentiality
endorsement, and an endorsement stating “File Produced Natively.”
If documents requested in native format require redactions, the
parties should ensure that proper formatting and usability are
maintained. The requesting party will identify to the producing party
redacted documents whose formatting or usability has been
unreasonably degraded, and the parties will meet and confer to agree
on reasonable modifications to the production format.
3.

If a spreadsheet-type file must be redacted, and the image file
exceeded 15 pages, only the first 15 pages of that spreadsheet need
to be redacted and the remainder may be slipsheeted with a TIFF
image slip-sheet noting that “Additional Pages Exceeding Redaction
Threshold”.

C.

Redactions: As set forth in the Protective Order, The Producing Party may

redact from any TIFF image, metadata field, or native file material that is protected from disclosure
by applicable privilege or immunity. materials, and other information that it is not permitted by
laws and regulations to be disclosed in litigation even with Court-imposed confidentiality
restrictions. Parties may also redact potentially sensitive personal identifying information of NonParties. Should the need arise, the Parties will meet and confer on the appropriateness of a given
redaction. The Producing Party shall identify redactions clearly on the face of any TIFF image,
either with “Redacted” or the redaction reason on the face of the Document if space allows (e.g.,
Privilege, Privacy, etc.).

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D.

Technical Issues: If a document which would otherwise be produced in

TIFF format cannot be imaged for technical reasons, it may also be produced in native format as
described above, in which case the slip-sheets will display the Bates number of the native file and
an endorsement stating “Document Unable To Be Imaged.”
E.

Color: Documents containing color need not be produced in color in the

first instance, provided that the Producing Party shall retain a copy of produced hard copy
documents in color. The Producing Party will honor reasonable requests for a color image of a
document, if production in color is necessary to understand the meaning or content of the
document. The Requesting Party may request production of such documents in color by providing
(1) a list of the Bates numbers of documents it requests to be produced in color format; and (2) an
explanation of the need for production in color format. The Producing Party shall not unreasonably
deny such requests. The Parties reserve the right to allocate costs of color productions if they
become burdensome, and any such requests are subject to the boundaries of proportionality.
F.

Metadata: All ESI should be produced with a DAT file that contains the

metadata fields listed in Schedule A annexed hereto, to the extent captured at the time of the
collection. Metadata should not be removed from any document produced in native format.
1.

To the extent that metadata does not exist or is not reasonably
accessible or available for any documents produced, nothing in this
ESI Order shall require any Party to create, extract, capture, collect
or produce such metadata.

2.

An accompanying OPT file should also be provided for all TIFF
images. TIFF images should show any and all text and images which
would be visible to the reader using the native software that created
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the document. For example, TIFF images of email messages should
include the BCC line, and TIFF images of MS Word documents
should show all tracked changes and comment.
G.

Text Files: For all ESI produced, an accompanying document level text file

containing either the Extracted Text or OCR text from the document should be produced. The file
path and file name of the plain text file should be included in the “TEXTLINK” field of the DAT
file.
H.

Parent-Child Relationships: Due to the contextual relationship of ESI, the

Parties will maintain family relationships for electronic data. The Parties agree that if any part of
a document or its attachments is responsive, the entire document and attachments must be produced,
except any attachments that must be withheld or redacted on the basis of any privilege or workproduct or other protection. However, in an effort to avoid unnecessary expense and burden, the
Parties agree that completely non-responsive documents attached to a responsive document may be
produced as a single-page Bates-stamped TIFF image slip-sheet stating the document has been
withheld as non-responsive and slip sheet metadata produced as identified in Schedule A. When
producing responsive attachments, the parent email will be produced, regardless of responsiveness
unless otherwise protected from disclosure. Each document shall be produced with the production
number for the first and last page of that document in the “BegBates” and “EndBates” fields of the
data Load File and with the “BegAttach” and “EndAttach” fields listing the production number for
the first and last page in the document family.
VI.

PRODUCTION FORMAT FOR STRUCTURED DATA

To the extent a response to a non-objectionable discovery request requires production of
discoverable electronic information contained in a database, the parties will meet and confer to
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address the most appropriate and cost-effective production format for the production and
production format of any responsive data contained in a database or other structured or aggregated
data source or otherwise maintained by an application, which may include running a report or a
database export. The Parties will reasonably cooperate in the exchange of information concerning
such databases to facilitate discussions on productions and production format. If the Parties cannot
reach agreement, the requesting party will make a motion to compel the information.
VII.

PRODUCTION FORMAT FOR MEDIA

Documents shall be exchanged on DVD-ROMs, CD-ROMs, USB drives, portable hard
drives or through secure file transfer protocols (e.g., FTP) or similar secure electronic transmission.
The production media shall be labeled with the Volume Number along with the Bates Number
range(s) of the materials, date of delivery, and where not practicable to do so, may be provided in
an accompanying letter. If a hard drive contains multiple volumes, each volume should be
contained in an appropriately named folder at the root of the drive. Volumes should be numbered
consecutively (ABC001, ABC002, etc.). Any document production that may contain material
subject to the Protective Order shall be produced in encrypted form and the production media shall
be labeled accordingly. If a Producing Party encrypts or “locks” the production, the Producing
Party shall send, under separate cover, an explanation of how to decrypt the production.
VIII. PROCESSING SPECIFICATIONS
A.

Time Zone: All Parties will identify the time zone in which its data is

processed as reflected in the metadata.
B.

Global or Horizontal Deduplication: All Parties shall make reasonable

efforts to de-duplicate ESI. ESI produced shall be globally de-duplicated across all collected
custodial and non-custodial sources. Removal of duplicate documents should only be done on
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exact duplicate documents (based on MD5 or SHA-1 hash values, at the family level). Attachments
should not be eliminated as duplicates for purposes of production, unless the parent email and all
attachments are also duplicates. An email that includes content in the BCC or other blind copy field
should not be treated as a duplicate of an email that does not include content in those fields, even
if all remaining content in the email is identical. The initial custodian of a document should be
listed in both the CUSTODIAN and ALL CUSTODIAN fields and subsequent custodians'
deduplicated copies of the document should be listed in the ALL CUSTODIANS field, with each
custodian name separated by a semicolon.
C.

Email Thread Suppression: A party may produce a single copy of a

responsive document insofar as no non-duplicative information is lost as a result. For emails with
attachments, the hash value is generated based on the parent/child document grouping. A party
may also de-duplicate email threads as follows: in an email thread, only the last-in-time portion of
the thread that is relevant needs to be produced if all previous emails in the thread are contained
within the final message(s). Where an email is not last-in-time and contains an attachment, that
email and its attachment shall be considered for production.
D.

System Files: Each Party will “de-NIST” system and application files

unless they are determined by the producing party to be responsive.
IX.

BATES NUMBERS

Bates numbering should be consistent across the production, contain no special characters,
and be numerically sequential within a given document. If a Bates number or set of Bates numbers
is skipped, the skipped number or set of numbers should be noted with a placeholder. Attachments
to documents will be assigned Bates numbers that directly follow the Bates numbers on the

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documents to which they were attached. In addition, wherever possible, each *.tiff image will have
its assigned Bates number electronically “burned” onto the image.
X.

IDENTIFICATION AND COLLECTION OF DOCUMENTS
Except as otherwise agreed upon in this ESI Order, the Parties will meet and confer

periodically regarding the scope of discovery, prioritizing collection and production efforts,
methods of ESI collection, including agreements on (i) custodians and business records, (ii) data
sources, including joint data sources managed or accessed by multiple employees, (iii) search
terms, (iv) email addresses or domains, and (v) date restrictions by matter or custodian, and
memorialize in writing any agreements reached. As part of these discussions, Counsel for the
respective Defendants will disclose to Plaintiffs the Custodians most likely to possess responsive
ESI and hard copy documents.
XI.

TECHNOLOGY-ASSISTED REVIEW

The parties may use technology assisted review (“TAR”).
XII.

EXCLUDED FILE TYPES

Absent a particularized need and good cause showing, the circumstances of this case do
not warrant the preservation, collection, review, or production of ESI from the sources noted below
because they are either not reasonably accessible or it is anticipated that enough relevant
information can be yielded from accessible sources and, as necessary and appropriate,
supplemented with deposition discovery. The following ESI does not require preservation,
collection, review or production:
1.

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

only accessible by specialized computer forensics tools and methods.

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2.

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

that is difficult to preserve without disabling the operating system.
3.

Online access data such as temporary Internet files, history, cache, cookies

4.

Data stored on photocopiers, scanners, and fax machines.

5.

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

and the like.

last accessed dates, last printed dates, and last saved dates, so long as at the time the data is
collected for inclusion on Schedule “A” nothing is done to scrub, remove or alter in any way the
data from the native files.
6.

Back-up data that are substantially duplicative of data that are more

accessible elsewhere.
7.

Server, system, or network logs.

8.

Data remaining from systems no longer in use that is unintelligible on the

systems in use.
9.

Email, calendars, and contact data sent to or from mobile devices (e.g.,

iPhone, iPad, Android, and Blackberry devices) that are duplicative of data that are more accessible
elsewhere.
Nothing herein shall prevent a Party from subsequently requesting that ESI or other
Documents identified above be preserved and produced if specific facts demonstrate a particular
need for such evidence that justifies the burden of preservation and retrieval.
XIII. PRIVILEGE AND PRIVILEGE LOGS
A.

Privilege Log: A Party that withholds documents, ESI, and any other

materials and information on the grounds of attorney-client privilege, attorney work product,
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and/or any other applicable privilege, immunity or protection from discovery, shall produce a
privilege log. The privilege log shall list the specific privilege or privileges asserted regarding
each withheld document and describe the document with sufficient particularity to allow the
receiving Party to assess the claim of privilege but without revealing privileged information. The
privilege log shall, to the extent available, include the date the document was prepared, the person
or persons who prepared the document, and the person or persons to whom the document was
addressed, directly and by carbon copy or blind copy. The privilege log shall indicate whether any
identified sender or recipient of the document was acting in the capacity of attorney for the Party.
The privilege log shall include the subject and or title of the document without revealing privileged
or protected information.
1.

Materials Not Required to be Logged. The following documents
presumptively need not be included on a privilege log:
a.

Privileged communications exclusively between a Party and
its counsel and/or staff or agents of counsel related to
representation in this case where no other party or third party
is also included in the communication.

b.

Privileged communications exclusively involving outside
counsel, where no Parties to this action or any third party is
included, copied, or blind-copied.

c.

Work product created by in-house or outside counsel, or by an
agent of in-house or undersigned counsel for this litigation.

d.

Non-substantive embedded files in privileged documents
(i.e., images, logos, et cetera).
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2.

Logging Email Threads. For purposes of creation of a privilege
log, a Party need include only one entry on the log to identify
withheld privileged emails that constitute an uninterrupted dialogue
between or among individuals; provided, however, that disclosure
must be made that the emails are part of an uninterrupted privileged
dialogue.

3.

Time for Serving Privilege Log. Privilege logs shall be produced
in accordance with the Federal Rules of Civil Procedure and any
applicable local rules and procedures.

B.

Reservation on Privilege Logs. The Parties reserve their rights to revisit

the date after which documents need not be included on a privilege log and may modify the agreed
upon date(s) by mutual agreement. The Parties further agree to meet-and-confer regarding any
proposed additional categories of documents that presumptively need not be logged.
XIV. THIRD PARTY DOCUMENTS
A Party that issues a non-Party subpoena (“Issuing Party”) shall include a copy of this ESI
Order 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. Nothing in this ESI
Order 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.
XV.

GOOD FAITH
A.

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

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

Parties agree to identify the documents by including the Bates number of

the first page of the document at issue so long as the document was produced by the parties in this
litigation through discovery obtained in this litigation. Nothing in this paragraph is meant to
preclude the parties from otherwise using documents which were not necessarily produced as
a result of discovery in this litigation.
IT IS SO ORDERED.
Date: March 11, 2025

/s/ Elizabeth A. Preston Deavers
ELIZABETH A. PRESTON DEAVERS
UNITED STATES MAGISTRATE JUDGE

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SCHEDULE A
Field

Data Type

BegDoc
EndDoc
BegAttach

Integer - Text
Integer - Text
Integer - Text

EndAttach

Integer - Text

Custodian

Text

DupCustodian

Text – paragraph
Separate entries
with “;”

Folder

Text

From
To

Text - paragraph
Text – paragraph
Separate entries
with “;”
Text – paragraph
Separate entries
with “;”
Text – paragraph
Separate entries
with “;”
Text - paragraph
Date
(mm/dd/yyyy)
Time (hh:mm:ss)
Date
(mm/dd/yyyy)
Time (hh:mm:ss)
Text - paragraph

CC
BCC
Subject
DateSent
TimeSent
DateReceived
TimeRecv
FileName
FileExtension
DateCreated
DateModified
Title

Paper
Starting Bates #
Ending Bates #
Starting bates # of
document family
Ending bates # of
document family
Name of person the
document was
collected from

Native Files &
Email Attachments
Starting Bates #
Ending Bates #
Starting bates # of document
family
Ending bates # of document
family
Name of person the
document was collected from

Email

Starting Bates #
Ending Bates #
Starting bates # of
document family
Ending bates # of
document family
Name of person the
document was collected
from
All names of people the
All names of people the
document was collected
document was collected
from even if removed from
from even if removed from
production as a duplicate
production as a duplicate
File path/folder structure for File path/folder structure for
the original native file as it
the original native file as it
existed at the time of collection existed at the time of
collection. Should include
full path and folder
locations of email container
files such as PST and NSF
and the internal
path of the email within
those files
Sender of message
Recipients of message
Copied recipients
Blind copied recipients
Subject of message
Date message sent
Time message sent
Date message received
Name of original file
including extension
Extension of original file
Date file was created

Text
Date/Time
(mm/dd/yyyy)
Date/Time
(mm/dd/yyyy)
Text - paragraph

Date file was last modified
Title from document
metadata

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Time message received
Name of original file
including extension
Extension of original file

Author

Text - paragraph

Document author from
metadata
Document company or
organization from metadata
MD5 or SHA-1 Hash Value
of document
Path including filename to
the associated native file if
produced (Relative Path)
Path including filename to
Path including
the associated searchable
filename to the
associated searchable text file (Relative Path)
text file
(Relative Path)
Designation branded Designation branded onto the
onto the
document
document
Physical location, computer
or server from which the
data was collected

Company

Text - paragraph

FileHash

Text

NativeLink

Text - paragraph

TextLink

Text - paragraph

Confidentiality

Single choice

Source

Text – paragraph

Type of
Redaction

Text multiple
choices
(attorney/client;
work product etc)

Last Accessed
Date
Last Saved Date

Date
(mm/dd/yyyy)
Date
(mm/dd/yyyy)

Last date file was accessed

Last date file was accessed

Last Date saved

Last date saved

Last Printed

Date
(mm/dd/yyyy)

Last Date printed

Last date printed

Slip-Sheet reason

Text – multiple
choices filed,
privilege, nonresponsive, etc.

Text – multiple choices filed,
privilege, non- responsive,
etc.

Text – multiple choices
filed, privilege, nonresponsive, etc.

MD5 or SHA-1 Hash
Value of document
Path including filename to the
associated native file if
produced (Relative Path)
Path including filename to
the associated searchable
text file (Relative Path)
Designation branded onto
the document
Physical location, computer
or server from
which the data was collected
Text multiple choices
(attorney/client; work
product etc)

Text – multiple
choices filed,
privilege, nonresponsive, etc.