Filed: Apr. 30, 2018
Latest Update: Apr. 30, 2018
Summary: THE PARTIES' STIPULATION AND [PROPOSED] ORDER REGARDING DISCOVERY OF EMAILS AND ATTACHMENTS RICHARD SEEBORG , District Judge . Pursuant to the Court's minute order following the initial case management conference held in this case on April 19, 2018, ECF No. 53, Plaintiff Collateral Analytics, LLC and Defendants Nationstar Mortgage LLC, Xome Settlement Services, LLC, and Quantarium, LLC (together, the "Parties") held a further meet and confer regarding discovery of emails and their att
Summary: THE PARTIES' STIPULATION AND [PROPOSED] ORDER REGARDING DISCOVERY OF EMAILS AND ATTACHMENTS RICHARD SEEBORG , District Judge . Pursuant to the Court's minute order following the initial case management conference held in this case on April 19, 2018, ECF No. 53, Plaintiff Collateral Analytics, LLC and Defendants Nationstar Mortgage LLC, Xome Settlement Services, LLC, and Quantarium, LLC (together, the "Parties") held a further meet and confer regarding discovery of emails and their atta..
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THE PARTIES' STIPULATION AND [PROPOSED] ORDER REGARDING DISCOVERY OF EMAILS AND ATTACHMENTS
RICHARD SEEBORG, District Judge.
Pursuant to the Court's minute order following the initial case management conference held in this case on April 19, 2018, ECF No. 53, Plaintiff Collateral Analytics, LLC and Defendants Nationstar Mortgage LLC, Xome Settlement Services, LLC, and Quantarium, LLC (together, the "Parties") held a further meet and confer regarding discovery of emails and their attachments. The Parties respectfully submit the following protocol to limit the discovery of emails and their attachments in this case:
1. Within twenty-one (21) days from the service of a request for production ("RFP") for emails and their attachments, the Parties shall meet and confer to develop a list of custodians and search terms that the Responding Party will use to search for, review, and produce any emails and attachments responsive to the RFP.
2. At least seven (7) days before the meet and confer the Propounding Party shall serve a proposed list of custodians and search terms for each of the Propounding Party's RFPs that requests emails and their attachments.
3. At the meet and confer, the Responding Party shall be prepared to discuss the number of emails that contain each of the search terms by custodian (i.e., the hit counts) identified in the Propounding Party's proposed list. The Parties agree to negotiate the list of search terms and custodians in good faith, taking into account the hit counts for the search terms and custodians and the subject matter of the RFP.
4. Nothing in this protocol shall be interpreted to require disclosure of irrelevant information or relevant information protected by the attorney-client privilege, work-product doctrine, or any other applicable privilege or immunity. The Parties do not waive any objections as to the production, discoverability, admissibility, or confidentiality of emails and their attachments, and reserve all rights to seek appropriate relief from the Court.
FILER'S ATTESTATION
Pursuant to Civil L.R. 5-1(i)(3), regarding signatures, I, Lauren E. Kapsky, attest that concurrence in the filing of this document has been obtained.
[PROPOSED] ORDER
PURSUANT TO STIPULATION, IT IS SO ORDERED.
