Filed: Feb. 21, 2017
Latest Update: Feb. 21, 2017
Summary: STIPULATION AND [PROPOSED] ORDER RE PROCESS FOR PRODUCTION OF ELECTRONICALLY STORED INFORMATION (ESI) JON S. TIGAR , District Judge . WHEREAS, on February 16, 2017, the Court instructed Plaintiffs and PricewaterhouseCoopers LLP ("PwC"), to meet and confer regarding electronically stored information ("ESI") and file this stipulation; WHEREAS, today, the Court entered a Minute Order, ECF No. 72, instructing the Parties to submit, today, "a joint stipulation or competing proposals estab
Summary: STIPULATION AND [PROPOSED] ORDER RE PROCESS FOR PRODUCTION OF ELECTRONICALLY STORED INFORMATION (ESI) JON S. TIGAR , District Judge . WHEREAS, on February 16, 2017, the Court instructed Plaintiffs and PricewaterhouseCoopers LLP ("PwC"), to meet and confer regarding electronically stored information ("ESI") and file this stipulation; WHEREAS, today, the Court entered a Minute Order, ECF No. 72, instructing the Parties to submit, today, "a joint stipulation or competing proposals establ..
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STIPULATION AND [PROPOSED] ORDER RE PROCESS FOR PRODUCTION OF ELECTRONICALLY STORED INFORMATION (ESI)
JON S. TIGAR, District Judge.
WHEREAS, on February 16, 2017, the Court instructed Plaintiffs and PricewaterhouseCoopers LLP ("PwC"), to meet and confer regarding electronically stored information ("ESI") and file this stipulation;
WHEREAS, today, the Court entered a Minute Order, ECF No. 72, instructing the Parties to submit, today, "a joint stipulation or competing proposals establishing a date for the submission of a discovery letter brief addressing ESI";
WHEREAS, the Parties have met and conferred by telephone today and reached agreement on a process for ESI discovery and a deadline for submission of any disagreement regarding ESI discovery;
THEREFORE, IT IS HEREBY STIPULATED that:
• Wednesday, March 1, 2017: Plaintiffs will provide to PwC their opening proposal regarding custodians, sources of ESI, and potential search terms, noting which search terms are related to which document requests. Plaintiffs intend to include some questions regarding who the most appropriate custodians should be for certain topics; PwC reserves all rights with respect to the propriety of such questions. The parties may use traditional search terms or another method, such as technology-assisted review ("TAR"), depending on their negotiations in the next step.
• March and April 2017: The parties will negotiate regarding custodians, sources, search process (e.g., traditional search terms, TAR, etc.).
• Friday, April 28, 2017: The parties will file a notice stating either (a) their agreement as to these issues or (b) their need to file a joint letter brief regarding areas of disagreement by May 9, 2017
PURSUANT TO THE STIPULATION, IT IS SO ORDERED.
