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WASHINGTON v. KINDRED HEALTHCARE, INC., 4:15-cv-04528-KAW. (2016)

Court: District Court, N.D. California Number: infdco20160729906 Visitors: 3
Filed: Jul. 28, 2016
Latest Update: Jul. 28, 2016
Summary: STIPULATION AND [ PROPOSED ] FEDERAL RULE OF EVIDENCE 502(d) ORDER KANDIS A. WESTMORE , Magistrate Judge . To facilitate discovery in this matter, the parties respectfully request the Court enter the following order pursuant to Federal Rule of Evidence 502(d): The production of privileged or work-product protected documents, electronically stored information ("ESI") or other information, whether inadvertent or otherwise, is not a waiver of the privilege or protection from discovery in
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STIPULATION AND [PROPOSED] FEDERAL RULE OF EVIDENCE 502(d) ORDER

To facilitate discovery in this matter, the parties respectfully request the Court enter the following order pursuant to Federal Rule of Evidence 502(d):

The production of privileged or work-product protected documents, electronically stored information ("ESI") or other information, whether inadvertent or otherwise, is not a waiver of the privilege or protection from discovery in this case or in any other federal or state proceeding. This Order shall be interpreted to provide the maximum protection allowed by Federal Rule of Evidence 502(d). Nothing contained herein is intended to or shall serve to limit a party's right to conduct a review of documents, ESI or information (including metadata) for relevance, responsiveness and/or segregation of privileged and/or protected information before production.

IT IS SO STIPULATED.

[PROPOSED] ORDER

IT IS SO ORDERED.

Source:  Leagle

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