Order by Magistrate Judge Donna M. Ryu granting 127 Stipulation — In re Plaid Inc. Privacy Litigation (Dkt. 128, N.D. Cal. No. 4:20-cv-03056)

Record facts

U.S. District Court for the Northern District of California · No. 4:20-cv-03056-DMR · Doc. 128 · 2021-05-19 · Docket on CourtListener

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STIPULATION AND ORDER REGARDING THE 
PRODUCTION OF ELECTRONICALLY STORED 
INFORMATION (“ESI”) AND HARD COPY  
 
HERRERA KENNEDY LLP 
Shawn M. Kennedy (SBN 218472) 
skennedy@herrerakennedy.com 
4590 MacArthur Blvd., Suite 500 
Newport Beach, CA 92660 
Tel: (949) 936-0900 
Fax: (855) 969-2050 
 
LIEFF CABRASER HEIMANN & 
BERNSTEIN, LLP 
Rachel Geman (Pro Hac Vice) 
rgeman@lchb.com 
250 Hudson Street, 8th Floor 
New York, NY 10013-1413 
Tel: (212) 355-9500 
Fax: (212) 355-9592 
BURNS CHAREST LLP 
Christopher J. Cormier (Pro Hac Vice) 
ccormier@burnscharest.com 
4725 Wisconsin Avenue, NW, Suite 200 
Washington, DC 20016 
Tel: (202) 577-3977 
Fax: (469) 444-5002 
 
Interim Co-Lead Class Counsel 
(Additional counsel on signature page) 
COOLEY LLP 
Michael G. Rhodes (SBN 116127) 
rhodesmg@cooley.com 
Whitty Somvichian (SBN 194463) 
wsomvichian@cooley.com 
Kyle C. Wong (SBN 224021) 
kwong@cooley.com 
Lauren J. Pomeroy (SBN 291604) 
lpomeroy@cooley.com 
Ellie Barczak (SBN 329180) 
ebarczak@cooley.com 
101 California Street, 5th Floor 
San Francisco, CA 94111-5800 
Tel:  (415) 693-2181 
Fax: (415) 693-2222 
 
Attorneys for Defendant PLAID INC. 
UNITED STATES DISTRICT COURT 
NORTHERN DISTRICT OF CALIFORNIA                                                       
OAKLAND DIVISION 
IN RE PLAID INC. PRIVACY  
LITIGATION 
Master Docket No.: 4:20-cv-03056-DMR 
 
JOINT STIPULATION AND ORDER 
REGARDING THE PRODUCTION OF 
ELECTRONICALLY STORED 
INFORMATION (“ESI”) AND HARD 
COPY DOCUMENTS 
  
 
 
THIS DOCUMENT RELATES TO:  
ALL ACTIONS 
 
 
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STIPULATION AND ORDER REGARDING THE 
PRODUCTION OF ELECTRONICALLY STORED 
INFORMATION (“ESI”) AND HARD COPY 
 
I. 
PURPOSE 
This Stipulation and Order (“Order”) regarding the production of Electronically Stored 
Information (“ESI”) and Hard Copy Documents (collectively, “Document” or “Documents”) shall 
govern discovery of Documents in this case as a supplement to the Federal Rules of Civil Procedure, 
and any other applicable orders and rules.  Nothing in this Order is intended to expand or limit the 
parties’ obligations under the Federal Rules of Civil Procedure.  Any disputes arising out of the 
production of documents subject to this Order shall be resolved according to Federal Rules of Civil 
Procedure, Local Rule 26, and the Court’s Standing Orders. 
II. 
COOPERATION 
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. 
III. 
PRESERVATION AND IDENTIFICATION OF ESI 
The Parties have discussed their preservation obligations and needs and agree that 
preservation of potentially-relevant ESI will be reasonable and proportionate. 
1.  When a party propounds discovery requests pursuant to Fed. R. Civ. P. 34, the parties agree 
to phase the production of ESI.  Within a reasonable time following receipt of the requesting party’s 
requests for production of documents, the receiving party shall disclose the names of individuals 
and/or sources from which the producing party initially plans to collect documents in response to 
the document requests. The custodians shall be identified by name, title, and job description. 
Following the initial production, the parties will continue to prioritize the order of subsequent 
productions as necessary. The Parties shall have a continuing obligation to take reasonable and 
proportional steps to identify and preserve custodial and non-custodial data sources that may 
contain information that is relevant and proportional to the needs of the case and to the claims and 
defenses in this litigation. See FRCP 26(b)(1).  
2. If a producing party is aware of inaccessible data that is likely to contain unique, 
discoverable ESI that may be relevant to the claims and defenses in this litigation, it will identify 
the source from which it claims the data is not reasonably accessible to the receiving party.   
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STIPULATION AND ORDER REGARDING THE 
PRODUCTION OF ELECTRONICALLY STORED 
INFORMATION (“ESI”) AND HARD COPY 
 
3. Plaid has represented that it maintains dynamic databases which automatically overwrite 
data that may be relevant and discoverable in this action and that preserving such data in full would 
impose an undue burden on Plaid.  The parties agree to meet and confer and attempt to resolve this 
issue by June 8, 2021, and, to submit any unresolved dispute to the Court for resolution. 
a. Examples of data the Parties agree not to preserve include but are not 
necessarily limited to:  
i. ESI created or received before 1/1/2012 or after final judgment in 
this action; 
ii. Deleted, “slack,” fragmented, or unallocated data only accessible by 
forensics;  
iii. Random Access Memory (RAM), online access data such as 
temporary internet files, history, cache, and cookies; 
iv. Structural files not material to individual file contents (e.g. .CSS, 
.XSL, .XML, .DTD, etc.). 
4. The Parties agree to timely meet and confer as needed to resolve any disagreements 
regarding whether preservation of data from particular sources, in whole or in part, is reasonable 
and proportional to the needs of this case and to submit any unresolved disputes to the Court for 
resolution. 
IV. 
SEARCH & REVIEW 
1. 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 
potentially relevant and thus subject to production in discovery and filter out ESI that is not subject 
to discovery.  The Parties will meet and confer to discuss the use of search terms, filters, and date 
ranges for the purposes of production, and if possible to come to agreed-upon custodians and search 
terms, though productions of responsive, non-privileged documents may begin before an 
agreement, if one is possible, has been reached on these items.  
2. No party will use advanced culling techniques or technology assisted review processes to 
exclude documents from manual review or production without first conferring with the opposing 
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STIPULATION AND ORDER REGARDING THE 
PRODUCTION OF ELECTRONICALLY STORED 
INFORMATION (“ESI”) AND HARD COPY 
 
party.  The Parties agree to timely meet and confer as needed to resolve any disagreements 
regarding whether collection from particular sources is reasonable and proportional to the needs of 
this case and/or specific discovery requests and to submit any unresolved disputes to the Court for 
resolution.  
V. 
PRODUCTION FORMATS 
The Parties agree to produce documents in the formats set forth in Appendices 1 and 2 to 
this Order. 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 of the document production process. 
VI. 
DOCUMENTS PROTECTED FROM DISCOVERY 
1. Pursuant to Fed. R. Evid. 502(d), the production of a privileged or work-product-protected 
document (including both paper documents and electronically stored information), whether 
inadvertent or otherwise, shall be governed by the protective order entered into in this case. 
2. If the producing party redacts information from a page, the producing party shall “burn” a 
white box with visible text indicating that the document was redacted onto the document image 
over the information it intends to redact. If the producing party redacts a document, the metadata 
fields must nonetheless be produced to the extent the fields are already populated in the ordinary 
course, with the exception of email subject, which may be withheld from emails redacted on the 
basis that the email contains privileged or work-product materials where the email subject itself 
constitutes privileged or work-product material. Additional metadata fields deemed privileged may 
be redacted only to the extent necessary to protect the privilege. 
3. The parties agree to comply with this Court’s standing order for the appropriate scope and 
terms for privilege logs. Communications may be identified on a privilege log by category, rather 
than individually, if the parties agree that such communications are logged in sufficient detail for 
the opposing party to assess whether the assertion of privilege is justified. 
4. Communications between a party and its counsel in this litigation that post-date the filing 
of the complaint need not be placed on a privilege log.  
5. This stipulated agreement set forth in this section does not constitute a concession by any 
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STIPULATION AND ORDER REGARDING THE 
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INFORMATION (“ESI”) AND HARD COPY 
 
party that any documents are subject to protection by the attorney-client privilege, the work product 
doctrine or any other potentially applicable privilege or doctrine. This agreement also is not 
intended to waive or limit in any way either party’s right to contest any privilege claims that may 
be asserted with respect to any of the documents produced except to the extent stated in the 
agreement. 
VII. 
MODIFICATION 
This Order may be modified by a stipulation of the Parties or by the Court for good cause 
shown. 
VIII. MISCELLANEOUS PROVISIONS 
A. 
Objections Preserved. 
Nothing in this Order shall be interpreted to require disclosure of either irrelevant 
information or relevant information protected by the attorney-client privilege, attorney work-
product doctrine, or any other applicable privilege or immunity. Except as provided expressly 
herein, the parties do not waive any objections as to the production, discoverability, authenticity, 
admissibility, or confidentiality of Documents and ESI. 
B. 
Technical Variances. 
Recognizing that each producing party may experience production issues due to data 
systems or files that may not be fully compatible with the technical specifications set forth herein, 
any practice or procedure set forth herein may be varied by agreement of the parties, confirmed in 
writing, to accommodate such issues and/or where such variance is deemed appropriate to facilitate 
the timely and economical production of Documents or ESI. No party shall unreasonably object to 
any such variance. 
C. 
Reproduction as Natives. 
The parties agree that to the extent any party seeks production in native format of 
specifically identified ESI produced originally in TIFF form, the producing party shall respond 
reasonably and in good faith to any such request. 
 
 
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STIPULATION AND ORDER REGARDING THE 
PRODUCTION OF ELECTRONICALLY STORED 
INFORMATION (“ESI”) AND HARD COPY 
 
IT IS SO STIPULATED, through Counsel of Record. 
 
Dated:  May 14, 2021 
 
/s/ Melissa Gardner   
 
 
 
Michael W. Sobol (SBN 194857) 
Melissa A. Gardner (SBN 289096) 
LIEFF CABRASER HEIMANN & BERNSTEIN, LLP 
275 Battery Street, 29th Floor 
San Francisco, CA 94111-3339 
msobol@lchb.com 
mgardner@lchb.com 
Telephone: (415) 956-1000 
Fax: (415) 956-1008 
 
 
Rachel Geman (pro hac vice) 
Rhea Ghosh (Pro Hac Vice) 
LIEFF CABRASER HEIMANN & BERNSTEIN, LLP 
250 Hudson Street, 8th Floor  
New York, NY 10013-1413 
rgeman@lchb.com 
rghosh@lchb.com 
Telephone: (212) 355-9500 
Fax: (212) 355-9592 
 
 
 
Shawn M. Kennedy (SBN 218472) 
Bret D. Hembd (SBN 272826) 
HERRERA KENNEDY LLP 
4590 MacArthur Blvd., Suite 500 
Newport Beach, CA 92660 
skennedy@herrerakennedy.com 
bhembd@herrerakennedy.com 
Telephone: (949) 936-0900 
Fax: (855) 969-2050 
 
Nicomedes Sy Herrera (SBN 275332) 
Laura E. Seidl (SBN 269891) 
HERRERA KENNEDY LLP 
1300 Clay Street, Suite 600  
Oakland, CA 94612 
nherrera@herrerakennedy.com 
lseidl@herrerakennedy.com 
Telephone: (510) 422-4700 
 
 
 
Christopher J. Cormier (pro hac vice) 
BURNS CHAREST LLP 
4725 Wisconsin Avenue, NW, Suite 200 
Washington, DC 20016 
Telephone: (202) 577-3977 
Email: CCormier@BurnsCharest.com 
 
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STIPULATION AND ORDER REGARDING THE 
PRODUCTION OF ELECTRONICALLY STORED 
INFORMATION (“ESI”) AND HARD COPY 
 
 
Warren T. Burns (pro hac vice) 
BURNS CHAREST LLP 
900 Jackson Street, Suite 500 
Dallas, TX 75202 
wburns@burnscharest.com 
Telephone: (469) 904-4550 
Fax: (469) 444-5002 
 
 
C. Jacob Gower (pro hac vice) 
BURNS CHAREST LLP 
365 Canal Street, Suite 1170 
New Orleans LA 70130 
jgower@burnscharest.com 
Telephone: (504) 799-2845 
Fax: (504) 881-1765 
 
Interim Co-Lead Class Counsel 
 
  
Dated:  May 14, 2021 
/s/ Kyle C. Wong 
 
 
 
 
Michael G. Rhodes (SBN 116127) 
Whitty Somvichian (SBN 194463) 
Kyle C. Wong (SBN 224021) 
Lauren J. Pomeroy (SBN 291604) 
Ellie Barczak (SBN 329180) 
COOLEY LLP 
rhodesmg@cooley.com 
wsomvichian@cooley.com 
kwong@cooley.com 
lpomeroy@cooley.com 
ebarczak@cooley.com 
101 California Street, 5th Floor 
San Francisco, CA 94111-5800 
Tel:  (415) 693-2181 
Fax: (415) 693-2222 
 
 
Counsel for Defendant Plaid Inc. 
 
 
IT IS ORDERED that the foregoing Agreement is approved. 
 
Dated:  May 19, 2021  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Honorable Donna M. Ryu 
 
 
 
 
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STIPULATION AND ORDER REGARDING THE 
PRODUCTION OF ELECTRONICALLY STORED 
INFORMATION (“ESI”) AND HARD COPY  
 
APPENDIX 1 
PRODUCTION DELIVERY REQUIREMENTS 
I. 
GENERAL PRODUCTION PROVISIONS 
The parties agree that ESI should be produced as TIFF images and in Native format where 
applicable with accompanying data and image load files. If particular documents warrant a different 
format, the parties will cooperate to arrange for the mutually acceptable production of such 
documents.  
A. 
TIFF Image Files.  
The parties agree that all other Documents, with the exception of Documents produced in 
Native Format, will be produced as single-page black and white Group IV TIFF image files of at 
least 300 dpi resolution with 1 bit depth. Page size shall be 8.5 x 11 inches, unless in the reasonable 
judgment of the producing party, a particular item requires a different page size. Each image file 
will use the Bates number of the page as its unique file name. Original document orientation as 
displayed in the native file should be maintained in the TIFF image (i.e., portrait to portrait and 
landscape to landscape). 
B. 
Text Files.  
Each Document produced under this Order shall be accompanied by a document level text 
file containing all of the text for that document, not one text file per page. Each text file shall be 
named to use the Bates number of the first page of the corresponding document. The text files shall 
be generated by extracted text from native files and OCR text files from hard copy scanned 
documents as applicable. The .DAT load file shall include a link to the corresponding text file. 
C. 
OCR Text File.  
The parties will provide searchable OCR text of any paper or imaged Documents, unless 
doing so would be impracticable. In the case of impracticability, the producing party will produce 
the documents as they are kept in the ordinary course of business. 
D. 
Extracted Text Files from ESI.  
The parties shall extract the text of each ESI item directly from the ESI native file, where 
extracted text is reasonably available. For any calendar entries collected and/or processed after the 
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STIPULATION AND ORDER REGARDING THE 
PRODUCTION OF ELECTRONICALLY STORED 
INFORMATION (“ESI”) AND HARD COPY 
 
execution date of this Order, fields should be extracted and produced as text. 
E. 
OCR Text for Redacted Documents.  
The parties will provide searchable OCR text for any redacted files. 
F. 
Bates Numbering. 
1. 
Each TIFF image produced under this Order should be assigned a Bates 
number that must: (1) be unique across the entire document production; (2) maintain a constant 
length of nine numeric digits (including 0-padding) across the entire production; (3) contain only 
alphanumeric characters, no special characters or embedded spaces; and (4) be sequential within a 
given Document. The producing party will identify the Bates number range of each production in 
a cover letter or production log accompanying the production. If a producing party skips a Bates 
number or set of Bates numbers in a production, the producing party will identify and note the gap 
in the cover letter or production log accompanying the production.  
2. 
The producing party will brand all TIFF images in the lower right-hand 
corner with its corresponding Bates number, using a consistent font type and size. If the receiving 
party believes that a Bates number obscures the content of a Document, then the receiving party 
may request that the Document be produced with the Bates number in a different position. 
G. 
Re-Production of Prior or Other Litigation Documents.  
If re-production is required for a set of documents produced in a prior litigation or any other 
proceeding, or where a prior production of documents or ESI by a party in a prior litigation or any 
other proceeding is the only reasonably accessible source of those documents or ESI to be produced 
by a party in this litigation, the producing party may re-produce such documents in the manner in 
which they were produced in the prior case, including all objective coding or metadata fields 
required by this protocol to the extent reasonably available to the producing party as part of the 
productions set. For any such re-production in accordance with this Paragraph, the producing party 
is not obligated to re-format the prior production in accordance with the production specifications 
in ESI stipulation, but must provide Bates numbering and confidentiality designations specific to 
this litigation. 
H. 
Parent-Child Relationships.  
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STIPULATION AND ORDER REGARDING THE 
PRODUCTION OF ELECTRONICALLY STORED 
INFORMATION (“ESI”) AND HARD COPY 
 
Parent-child relationships for all embedded ESI documents (e.g., the association between 
an attachment and its parent email, or a spreadsheet embedded within a word processing document), 
must be preserved by assigning sequential Bates numbers to all items within the parent-child group, 
and identifying those Bates numbers in the relevant ESI metadata and coding fields specified in 
Appendix 2.  For example, if a party is producing an email with embedded attachments, the 
attachments must be processed and assigned Bates numbers in sequential order, following 
consecutively behind the parent email. Not all attachments may be produced – for example, 
privileged or nonresponsive attachments may be removed, but all documents within responsive 
families will be Bates numbered prior to production. 
I. 
Color Documents.  
If an original ESI Document contains color text, markings or graphics, and the receiving 
party believes it is necessary to view such Document in its original color to understand its full 
meaning or content, then the receiving party may request that the ESI Document be produced in 
color format. The producing party shall then reproduce such Document(s) and/or ESI in color JPEG 
format, or in native format. This section also applies to documents that are produced as TIFF 
images. 
J. 
Confidentiality Designations.  
If a particular Document has a confidentiality designation, the designation shall be stamped 
on the face of all TIFF images pertaining to such Document, in the lower left-hand corner of the 
Document, or as close thereto as possible while preserving the underlying image.  If the receiving 
party believes that a confidentiality designation obscures the content of a Document, then the 
receiving party may request that the Document be produced with the confidentiality designation in 
a different position. No party may attach to any filing or any correspondence addressed to the Court 
(including any Magistrate Judge), or any adverse or third party, or submit as an exhibit at a 
deposition or any other judicial proceeding, a copy (whether electronic or otherwise) of any native 
format Document produced by any party without ensuring that the corresponding Bates number 
and confidentiality legend appear in the file name of the document. For each document that is 
marked confidential, a Confidentiality field will be populated with the word “Confidential” in the 
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STIPULATION AND ORDER REGARDING THE 
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INFORMATION (“ESI”) AND HARD COPY 
 
.dat file.   In the event that the metadata confidentiality designation and the image designation do 
not match, the parties will assume the highest level of protection exists for the document and agree 
to notify the producing party of the issue promptly upon becoming aware of it.  Also, any documents 
marked Confidential must be handled in accordance with the Protective Order entered in this case. 
II. 
PRODUCTION OF HARD COPY DOCUMENTS 
All hard copy Documents that are scanned will be produced in electronic form. Where 
necessary and practicable, hard copy Documents in color will be scanned in color to ensure full 
information is communicated in the scanned copy. Scanned color documents will be provided in 
JPG file format. 
A. 
Unitization of Paper Document.  
To the extent practicable, hard copy Documents shall be unitized using logical document 
determinations or “LDD.” 
B. 
Identification. 
Where a Document or group of Documents has an identification spine, “post-it note,” or 
any other label, the information on the label shall be scanned and produced to the extent practicable. 
C. 
Custodian Identification. 
The parties will utilize reasonable best efforts to ensure that paper records for a particular 
custodian or department level custodian, which are included in a single production, are produced 
in consecutive Bates stamp order. 
D. 
Metadata.  
The metadata associated with each hard copy Document need only identify the Bates 
number, the custodian associated with that hard copy Document, and any Confidential Designation 
or Redaction applied to that Document. 
III. 
PRODUCTION OF “ESI” 
A. 
De-NISTING and System Files: ESI productions shall be de-NISTed using the 
industry standard list of such files maintained in the National Software Reference Library by the 
National Institute of Standards & Technology. De-NISTED files need not be produced. The parties 
may additionally exclude from review and production common system files and application 
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STIPULATION AND ORDER REGARDING THE 
PRODUCTION OF ELECTRONICALLY STORED 
INFORMATION (“ESI”) AND HARD COPY 
 
executable files.  Additional culling of system file types based on file extension may include, but 
are not limited to:  WINNT, LOGS, DRVS, C++ Program File (c) , C++ Builder 6 (cpp), Channel 
Definition Format (cdf), Creatures Object Sources (cos), Dictionary file (dic), Executable (exe), 
Hypertext Cascading Style Sheet (css), JavaScript Source Code (js), Label Pro Data File (IPD), 
Office Data File (NICK), Office Profile Settings (ops), Outlook Rules Wizard File (rwz), Scrap 
Object, System File (dll), Temporary File (tmp), Windows Error Dump (dmp), Windows Media 
Player Skin Package (wmz), Windows NT/2000 Event View Log file (evt), Python Script files (.py, 
.pyc, .pud, .pyw), Program Installers and the additional file extensions in Appendix 3 that are non-
standard, non-readable or non-reviewable file types. 
If a party excludes from review a standard, readable, and reviewable file type that is not 
listed above or in Appendix 3, that party must disclose such exclusion to the other parties. The 
parties further agree that, notwithstanding the file types listed above and in Appendix 3, no party 
shall exclude from review or withhold file types that are required to review responsive, non-
privileged substantive discovery. 
B. 
Native Files: Certain files types, such as presentation-application files (e.g., MS 
PowerPoint), spreadsheet-application files (e.g., MS Excel, .csv), and multimedia audio/visual files 
such as voice and video recordings (e.g., .wav, .mpeg, and .avi), shall be produced in native format. 
For files produced in native format, the producing party shall provide a single-page TIFF slip-sheet 
with the applicable Bates stamp indicating that a native item was produced. The corresponding load 
(.DAT) file shall include a NativeFileLink which provides the relative path linking information for 
each native file that is produced.  In addition, the confidentiality designation will be indicated in 
the name of the native file where reasonably feasible. 
C. 
Metadata Fields and Processing. 
1. 
ESI shall be processed in a manner that preserves the source native file and 
relevant metadata without modification, including their existing time, date, and time-zone metadata 
consistent with the requirements provided in this Order. The parties agree to process all data in 
Pacific Standard time. 
2. 
Hidden text. ESI shall be processed, to the extent practicable, in a manner 
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STIPULATION AND ORDER REGARDING THE 
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INFORMATION (“ESI”) AND HARD COPY 
 
that preserves hidden columns or rows, hidden text, notes, or worksheets, speaker notes, tracked 
changes, redlines and comments. Upon request, a producing party will produce files with any such 
information in native format. 
3. 
Compressed Files and Encrypted Files. Compressed file types (i.e., .CAB, 
.GZ, .TAR .Z, .ZIP) shall be decompressed in a reiterative manner to ensure that a zip within a zip 
is decompressed into the lowest possible compression resulting in individual files. The producing 
party will take reasonable steps, prior to production, to unencrypt any discoverable electronically 
stored information that exists in encrypted format (e.g., because password-protected) and that can 
be reasonably unencrypted. 
4. 
Microsoft “Auto” Feature and Macros. For Microsoft Excel (.xls/.xlsx), 
Microsoft Word (.doc), and Microsoft PowerPoint (.ppt) documents that contain “auto” features, 
(e.g., where documents have an automatically updated date and time in the document), the metadata 
associated with such files shall accurately reflect the automatically populated fields (i.e., the 
metadata date or other automatically populated field will reflect the date and/or entry for how the 
document was used or held in the ordinary course of business). 
5. 
Metadata and Coded Fields.  ESI items shall be produced with all of the 
metadata and coding fields set forth in Appendix 2. 
This Order does not create any obligation to create or manually code fields that are not 
automatically generated by the processing of the ESI, or that do not exist as part of the original 
metadata of the Document; provided, however, that the producing party must populate, where 
possible, the (a) BegBates, (b) EndBates, (c) BegAttach, (d) EndAttach, (e) Custodian, 
(f) NativeFileLink fields, if applicable, (g) TextPath, (h) Redaction status, and (i) Confidentiality 
designation. These fields should be populated for all produced ESI, as well as paper Documents 
converted to electronic form, regardless of whether the fields can be populated pursuant to an 
automated process. 
IV. 
DATABASES, STRUCTURED, AGGREGATED OR APPLICATION DATA 
1. 
The Parties will produce documents collected from databases or other structured 
databases in a reasonably useable format. If the data cannot be produced in a reasonably useable 
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format, the parties will meet and confer to address the production format. Prior to or during any 
such meet and confer, the producing party will provide sufficient information to enable the 
receiving party to evaluate the best method and format of production, If the parties cannot reach 
agreement, the matter will be decided by the Court or its designee. 
V. 
REDACTIONS. 
A. 
Redactions: 
The parties agree that where ESI items need to be redacted, they shall be produced in TIFF 
format with each redaction clearly indicated or where TIFF format is not practicable, in redacted 
native format, as noted below. Any unaffected data fields shall be provided. The redaction of any 
material for privilege or other reason shall be governed by the applicable rules and case law 
regarding privilege and the provisions contained in the Protective Order entered in this action. 
Spreadsheets that are to be produced in native format may be produced with redaction applied 
directly to the native file itself. If modification of a native file is required for redaction purposes, 
metadata information associated with that file should remain unchanged, unless it also requires 
redaction. For each document that is redacted, a Redaction field will be populated with the word 
“REDACTED” in the .DAT file.  Also, the producing party will keep a pristine original copy of 
the native document. 
B. 
Printing Specifications for Excel and PowerPoint files: 
In the event that a party produces Excel and PowerPoint type files in printed TIFF format 
for redaction and redacted, the following printing options shall be enabled: 
 
Excel Print to TIFF Options 
 Unhide columns and rows 
 Unhide worksheets 
 Autofit columns and rows, settings to be over by columns first and, then down by 
rows 
 Wrap text 
 Print gridlines 
 Do not apply Autofilter 
 Display headings 
 Display comments 
 Header and Footer filename field handling: Show field code 
 
 
PowerPoint Print to TIFF Options 
 Print notes pages 
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 Print hidden slides 
 Print comments 
1. 
The producing party shall also make reasonable efforts to ensure that any 
spreadsheets produced only as TIFF images because of redactions are formatted so as to be legible. 
For redacted items which were originally ESI, all metadata fields noted in this protocol that do not 
contain privileged or protected information will be provided and will include all non- redacted data. 
A document’s status as redacted does not relieve the producing party from providing all of the 
metadata required herein. 
C. 
De-duplication and Document Families: 
1. 
ESI shall be de-duplicated globally at the parent level using MD5 hash or 
SHA-1 hash.  For emails, de-duplication may be performed using a hash calculated using 
combination of metadata fields.  Such hash shall, at a minimum, account for all sender and recipient 
metadata including BCC recipients, the email subject, date sent, and attachment names.   
The parties are permitted to produce the longest unique email chain and do not need to 
separately produce the lesser-included emails unless those lesser-included emails have bcc 
recipients or unique attachments not included in the longest chain.  If a lesser-included email has a 
bcc recipient or unique attachment, then the lesser-included email must be separately produced with 
the attachments 
If a party produces only inclusive email, the parties agree to redact any privileged content 
or message component and produce in full the rest of the conversation in the inclusives.  
“Near duplicate” documents shall be produced rather than removed. The producing party 
need only produce a single copy of a particular ESI. 
The hash value for each item shall be reflected in the .DAT load file in the HashValue field 
specified in Appendix 2. In de-duplicating globally, the producing party shall identify custodians 
who were in possession of a de-duplicated Document in the AllCustodian metadata field specified 
in Appendix 2. This means that the field “AllCustodian” will be populated showing all custodians 
who had a copy of the same document which is not being produced because of de-duplication. 
2. 
De-duplication shall not break apart families and shall be performed at a 
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family level. A document and all other documents in its attachment range, emails with attachments 
and files with extracted embedded OLE documents all constitute family groups.  The producing 
party agrees that the presence of a custodian’s name contained in the “AllCustodian” field in the 
metadata for a particular document is evidence that the custodian possessed that document in his/her 
custodial file. 
D. 
Load Files: 
The data load file should be in standard Concordance format (.DAT). The .DAT file shall 
contain a relative path to the corresponding Native file. 
Concordance Data Load Files: 
The data load file should use standard Concordance delimiters: 
 Column - ¶ (ASCII 20); 
 Quote - þ (ASCII 254); 
 Newline - ® (ASCII 174). 
 The first line of the .DAT file should contain the field names arranged in 
the same order as the data is arranged in subsequent lines. 
 All date fields should be produced in mm/dd/yyyy format, if possible.  
Date fields may be combined date/time fields 
 All produced attachments should sequentially follow the parent 
Document/email. 
Sample Concordance .DAT Load File: 
þBegBatesþ¶þBegattatchþ¶þCustodianþ¶þNative Pathþ¶þExtracted Textþ 
þABC000001þ¶þABC000001þ¶þSampleþ¶þ\VOL001\NATIVES\001\ABC000001.xlsþ¶þTEXT\
001\ABC000001.t 
tþþABC000002þ¶þABC000001þ¶þSampleþ¶þNATIVES\001\ABC000002.gifþ¶þTEXT\001\AB
C000002.txtþ 
The image load file must be in standard Option (.OPT) format and must reference each TIFF 
file in the corresponding production, and the total number of TIFF files referenced in the load file 
must match the total number of image files in the production. The total number of Documents 
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referenced in a production’s data load file should match the total number of designated Document 
breaks in the corresponding image load file for that production. In any deliverable volume, 
documents should be organized in such a way that each folder in the volume contains 1000 files 
(each TIFF page or native file is a single file) as one file per folder. 
 Every image in the delivery volume should be cross-referenced in the 
image load file. 
 The imageID key should be named the same as the Bates number of the 
page. 
 Load files should not span across media (e.g., CDs, DVDs, hard drives, 
etc.), i.e., a separate volume should be created for each piece of media 
delivered. 
Sample Concordance/Opticon Image (.OPT) Load File: 
MSC000001,MSC001, \VOL001\IMAGES\001\MSC000001.TIF,Y„,2 
MSC000002,MSC001, \VOL001\IMAGES\001\MSC000002.TIF,,,, 
MSC000004,MSC001, \VOL001\IMAGES\001\MSC000004.TIF,Y,,,2 
MSC000005,MSC001, \VOL001\IMAGES\001\MSC000005.TIF,,,, 
OCR/Extracted Text Files: 
 OCR or Extracted Text files shall be provided in a separate directory containing 
Document level text files. The .DAT file shall contain a relative path to the 
corresponding text file. OCR or Extracted text itself should not be included in the 
.DAT file: 
PROD001\TEXT\001\ABC00015.txt 
 
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STIPULATION AND ORDER REGARDING THE 
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INFORMATION (“ESI”) AND HARD COPY  
 
APPENDIX 2: ESI METADATA AND CODING FIELDS 
The chart below describes the metadata fields to be produced, where reasonably available, 
in generic, commonly used terms which the producing party is to adapt to the specific types of 
ESI it is producing, to the extent such metadata fields exist associated with the original electronic 
Documents and are automatically generated as part of the electronic data discovery process. 
Ambiguities about a metadata field should be discussed with the receiving party prior to 
processing the subject ESI for production. 
Field Name 
Field Description 
BegBates 
  First Bates number (production number) of an item 
EndBates 
Last Bates number (production number) of an item 
**The EndBates field should be populated for single-page items. 
AttachName 
File name of the attachment, with any attachments separated 
by semi-colon. 
BegAttach/Group ID 
First Bates number of family group. 
EndAttach 
Last Bates number of attachment range (i.e., Bates number of 
the last page of the last attachment) 
PgCount 
Number of pages in the item 
Custodian 
Name of person or source from whose/which files the item is 
produced 
AllCustodian 
Name of the person(s), in addition to the Custodian, from 
whose files the item would have been produced if it had not 
been de- duplicated 
FileSize 
Size (in kilobytes) of the source native file 
SourceFilePath1 
The directory structure or path where the original file was 
stored on the party’s source computer system, ending in the 
filename. Any container name (such as ZIP or PST 
containers) is included in the path.2 
 
1 This field may be excluded if the producing party determines it includes information protected 
by any applicable privilege or immunity. 
2 This field may be excluded when producing documents from Google Vault, as this field is not 
supported.  
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Field Name 
Field Description 
HashValue 
The MD5 or SHA-1 hash value of the item 
NativeFileLink 
Relative path for documents provided in native format only 
**The linked file must be named per the BegBates value 
SourceParty 
Name of entity or party producing the item 
RecordType 
Indicates item type (e.g., email, edoc, attachment) 
FileType 
(e.g., Outlook, Adobe Acrobat, MS Word, etc.) 
FileExtension 
Indicates file extension of the file e.g., .docx, .pptx 
DateSent (mm/dd/yyyy) 
Date email or calendar item was sent 
TimeSent 
(hh:mmAM/PM) 
Time email or calendar item was sent (Date and time fields 
may be combined) 
DateReceived 
Date email or calendar item was received 
TimeReceived 
Time email or calendar item was received (Date and time 
fields may be combined) 
To 
The names and/or SMTP email addresses of all recipients that 
were included on the “To” line of the email or calendar item 
From 
The name and/or SMTP email address of the sender of the 
email or calendar item 
CC 
The names and/or SMTP email addresses of all recipients that 
were included on the “CC” line of the email or calendar item 
BCC 
The names and/or SMTP email addresses of all recipients that 
were included on the “BCC” line of the email or calendar item 
Number of Attachments 
Number of attached, embedded or grouped items 
DateCreated 
(mm/dd/yyyy) 
Date the item was created 
TimeCreated 
(hh:mm AM/PM) 
Time the item was created (Date and time fields may be 
combined) 
ModifiedBy 
Person who last modified or saved the item, as populated in 
the metadata or document properties of the native file 
LastModDate 
Date the item was last modified 
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Field Name 
Field Description 
(mm/dd/yyyy) 
LastModTime 
(hh:mm AM/PM) 
Time the item was last modified 
Date Last Printed 
Date the document was last printed 
FileName 
The filename of the source native file for an ESI item 
Title 
Any value populated in the Title field of the source file 
metadata or item properties 
Subject/E-Mail Subject 
Any value populated in the Subject field of the source file 
metadata or document properties (e.g., subject line of email 
or calendar item) 
Author 
Creator of the document; any value populated in the Author 
field of the source file metadata or document properties 
TextPath 
Full relative path to the location of the document-level text 
file 
Redacted 
User-generated field that will indicate redactions. With the 
word “REDACTED”. Otherwise, blank. 
Confidentiality 
User-generated field that will indicate confidentiality. With 
the word “CONFIDENTIAL” or “HIGHLY 
CONFIDENTIAL” or “ATTORNEYS EYES ONLY” 
applicable; Otherwise, blank 
X-RSMF-BeginDate3 
The begin date of the string of messages 
X-RSMF-EndDate 
The end date of the string of messages 
X-RSMF-EventCount 
The number of individual messages in a string 
 
 
 
 
3 X-RSMF fields shall be produced only if, and to the extent that, documents are produced in 
Relativity Short Message Format. 
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APPENDIX 3: NON-STANDARD OR NON-REVIEWABLE FILE TYPES 
The following file types are considered non-standard, non-readable, or non-reviewable file 
types that may be excluded without further disclosure: 
 
$P$; 3DMAP; 3M; ; A; ACCDB; ACL; ACRODATA; AD; AIFC; ANT; AODL; APB; 
ARD; ARF; ARSC; AS; ASE; AUTOMATICDESTINA; BAK; BCK; BIG; BIN; 
BINARZZZ; BLA; BLF; BLOG; BRO; C2; CAD; CATDRAWING; CATPART; 
CATPRODUCT; CC2; CDB; CDF-MS; CDG; CDM; CDR; CDX; CEL; CFS; CGM; CHK; 
CHM; CLASS; COM; CONTROL-7; CPIO; CPT; CRL; CSB; CSG; CSH; CSS; CST; 
CSX; CTB; CUSTOZZZ; CWD; DB6EC15298050000; DBF; DBT; DCM; DCT; 
DEFAULTS-7; DEL; DEX; DGM; DIB; DIR; DLL; DLLꞏ$EA; DMP; DNG; 
DOWN_ZZZ; DRM; DS_STORE; DYLIB; EDB; EL6; EMF; ENC; ENCR; EOT; EPT; 
ETL; EXE; FDT; FDX; FEED-MS; FEEDSDB-MS; FEV; FIL; FILE; File Extension; 
FIXML; FLA; FRQ; FSB; FSD; FSF; FT; GERMAN; GLA; GLZA; GR2; GRD; HASH; 
HCOM; HDR; HDS; HEU; HIR; HIV; HPGL; HTRI; HVS; HXD; HXH; HXW; I01; ICM; 
ICNS; ID; IDX; IGPI; IGR; IGS; ILL; INDD; INDEX; INFO; INIT; INSTALLED; IPT; 
ISU; ITDB; ITHMB; ITL; IWA; IXV; JCP; JFM; JNILIB; JOBOPTIONS; JS; JTX; KEY; 
KEYSTORE; LACCDB; LAY; LCK; LDB; LIC; LINUX; LNK; LOCALZZZ; LRU; 
M3D; M3G; MAP; MCX-7; MDB; META; MKV; MMD-7; MOBI; MODEL; MOM; 
MOVꞏ$ZZZ; MSI; MSO; MST; NIB; NOP; NRM; NWD; NYC; O; OAB; OBJ; OCX; 
ODL; ODLGZ; ODLSENT; ODTTF; OGG; OLD; OLE; OMO; ONE; ONECACHE; 
ONETOC2; OPERATIONS-7; OTC; OTF; OUT; P12; P7S; PAK; PB; PCB; PCK; PCM; 
PDB; PIC; PICKLE; PKGDAT; PKGX; PLIST; PLT001; PMA; POL; PREVIOUS; PRI; 
PRO; PRP; PRX; PSB; PTM; PVDB; PVF; PVR; PXM; PYC; PYO; PYRO; QXP; R1297; 
RBT; RDB; REGTRZZZ; REP; RES; RESOURCES; RLE; RNG; RPMSG; RSC; RVM; 
SAV; SBI; SCR; SDA; SDC; SDD; SDF; SDG; SDV; SDW; SER; SESSION; SHOCKED; 
SHS; SINF; SLDASM; SLDPRT; SMF; SNDT; SO; SQLITE; SQLITE3; SQLITZZZ; 
SQM; SRS; STAT; STH; STL; STORAGE; STORE; STP; STRINGS; SUPP; SVG; SWP; 
SWZ; SXC; SXI; T80; TAX; TBACCT; TBL; TBRES; TDE; TERATERM; THM; THMX; 
TMP; TRUSTSTORE; TTC; TTF; UMD; UP_META; USAGE; VBE; VMAS; VOL; 
VPOL; VPOLꞏZZZ; VSDX; VUE; VVS; WBT; WEBARCHIVE; WEBLOC; WEBP; 
WID; WOFF; XTERM-R6; XTERM-XFREE86; 0; ACP; APW; ASC; DBM; HMX; 
HYPER; KOA; P7M; PPROF; Q; RPM; SIG; SWO; TEXTCZZZ; TXZ; XPL; XZ; 0 - 
IZZZ; 00000ZZZ; 0-022ZZZ; ADAT; AMR; ARJ; ARLOLOGX; ASWCS; AWB; 
BACKUP; BLEND; BZ; CACHE; CAP; CER; CERT; CFE; CONFIG; CRDOWZZZ; 
CTRL; DAC; DB4; DCA; DEB; DER; DICT; DSK; DSX; DUMP; DVI; DXF; ECONFIG; 
EMC; ENCRYPT; EPS; EX_; FBCINDEX; FBCSEZZZ; FMT; FNM; FRX; FTS; 
GEMSPEC; GID; GLB; GMO; GPG; GZIP; HB; HLP; HTI; IPK; ISO; JASPER; JIO; JKS; 
KDB; KERN; KEYTAB; KS; LIB; LINKED; LZ4; M; MMPZ; NODE; NPS; ORC; 
PARQUET; PARTIAL; PCAP; PCAPNG; PDML; PFL; PGP; PIE; PKG; PKL; PKR; PL; 
PNM; POD; PP; PS; PWD; PY; QXD; RAM; RDATA; REDO; RENAMED; ROM; 
RPMNEW; SCC; SCSSC; SH; SI; SOLV; SOLVX; STATE; SVM; SWN; SXW; TABLES; 
TDB; TFEVENTS; TIM; TIP; TORRENT; TRUSTZZZ; TS; TXO; UN~; VCE; VDX; 
VERSION; WOFF2; WORKSZZZ; XCF; XPT; XZAA; XZAH; Z02; Z06; ZST 
 
 
 
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Filer’s Attestation 
Pursuant to Civil Local Rule 5-1(i)(3), I attest that concurrence in the filing of this 
document has been obtained from each of the other signatories.   
 
Dated:  May 14, 2021 
/s/ Melissa Gardner   
 
 
Melissa Gardner 
LIEFF CABRASER HEIMANN & BERNSTEIN, LLP 
 
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