STIPULATION AND (PROPOSED) ORDER FOR FORENSIC EXAMINATION OF PERFORMANCE EVALUATIONS OF DEFENDANT JENNIFER CAUDILLO

ROBERT M. ILLMAN, Magistrate Judge.

Plaintiff and Defendants CMGC, Taylor Fithian, M.D., Elaine Hustedt, and Claire Teske, R.N., by and through their respective attorneys of record, hereby stipulate to the following order being issued in this matter, after meeting and conferring about the forensic examination of performance evaluations of Jennifer Caudillo, LVN::

1. The office of Peter Bertling, Counsel for Defendants CMGC, Fithian, Hustedt, and Teske, shall send what may be all original performance evaluations for Jennifer Caudillo by Federal Express on November 20, 2017, to Plaintiff's document examiner:

2. Mr. Speckin will conduct forensic testing on the documents that may include: microscopic, infrared and ultraviolet light, ESDA testing for impressions, ink testing of a small sample of ink, all of which is generally accepted forensic document examination, which will not harm the legibility or evidentiary value of the document, and will not harm anyone else's ability to test the documents. Upon completion of the testing, Mr. Speckin will return the documents to Mr. Bertling by Federal Express with a sworn verification stating he has received the documents and is returning them to Mr. Bertling.

3. Plaintiff and the Defendants represented by Mr. Bertling shall have until December 29, 2017, to exchange any Rule 26 expert reports concerning the forensic examination of the Caudillo performance evaluations.

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

(PROPOSED) ORDER

PURSUANT TO STIPULATION, AND GOOD CAUSE APPEARING, IT IS SO ORDERED.