Case 2:22-cv-01599-KKE Document 73 Filed 11/20/23 Page 1 of 14
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`
`The Honorable Kymberly K. Evanson
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`
`
`
`UNITED STATES DISTRICT COURT
`WESTERN DISTRICT OF WASHINGTON
`AT SEATTLE
`
`STEVEN FLOYD, individually and on behalf of
`
`
`all others similarly situated,
`
`
`No. 2:22-cv-01599-KKE
`
`Plaintiff,
`
`
`PROTOCOL REGARDING
`v.
`
`DISCOVERY OF ELECTRONICALLY
`
`STORED INFORMATION AND
`AMAZON.COM, INC., a Delaware corporation,
`ORDER
`and APPLE INC., a California corporation,
`
`
`
`
`Defendants.
`
`
`
`A.
`
`General Principles
`An attorney’s zealous representation of a client is not compromised by conducting
`1.
`discovery in a cooperative manner. The failure of counsel or the parties to litigation to cooperate
`in facilitating and reasonably limiting discovery requests and responses raises litigation costs and
`contributes to the risk of sanctions.
`As provided in LCR 26(f), the proportionality standard set forth in Fed. R. Civ. P.
`2.
`26(b)(1) must be applied in each case when formulating a discovery plan. To further the
`application of the proportionality standard in discovery, requests for production of ESI and related
`responses should be reasonably targeted, clear, and as specific as possible. When a party
`propounds discovery requests pursuant to Fed. R. Civ. P. 34, the parties agree to meet and confer
`regarding the phasing and prioritization of productions.
`This Order may be modified by a Stipulated Order of the parties or by the Court
`3.
`Davis Wright Tremaine LLP
`PROTOCOL REGARDING DISCOVERY OF ELECTRONICALLY
`LAW OFFICES
`STORED INFORMATION AND ORDER
`920 Fifth Avenue, Suite 3300
`(Case No. 2:22-cv-01599-KKE) - 1
`Seattle, WA 98104-1610
`206.622.3150 main · 206.757.7700 fax
`
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`Case 2:22-cv-01599-KKE Document 73 Filed 11/20/23 Page 2 of 14
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`for good cause shown. Any such modified Order will be titled sequentially as follows, “First
`Modified Order re: Discovery of Electronically Stored Information for Standard Litigation,” and
`each modified Order will supersede the previous Order.
`Nothing in this Order precludes the parties from reaching further agreements on
`4.
`topics related to this Order, or if agreement cannot be reached, moving the Court for an
`appropriate discovery order.
`B.
`ESI Disclosures
`Within 60 days of any party’s first substantive responses to discovery requests, or at a
`later time if agreed to by the parties, each party shall disclose:
`1.
`Custodians. The custodians most likely to have discoverable ESI in their
`possession, custody, or control. The custodians shall be identified by name, title, connection to
`the instant litigation, and the type of the information under the custodian’s control. The parties
`shall meet and confer to reach agreement on a reasonable list of custodians for purposes of
`collection, review and production of electronically stored information.
`2.
`Non-custodial Data Sources. A list of non-custodial data sources (e.g., shared
`drives, servers), if any, likely to contain discoverable ESI.
`3.
`Third-Party Data Sources. A list of third-party data sources, if any, likely to
`contain discoverable ESI (e.g., third-party email providers, mobile device providers, cloud
`storage) and, for each such source, the extent to which a party is (or is not) able to preserve
`information stored in the third-party data source.
`4.
`Inaccessible Data. A list of data sources, if any, likely to contain discoverable ESI
`(by type, date, custodian, electronic system or other criteria sufficient to specifically identify the
`data source) that a party asserts is not reasonably accessible under Fed. R. Civ. P. 26(b)(2)(B).
`5.
`Foreign data privacy laws. Nothing in this Order is intended to prevent either party
`from complying with the requirements of a foreign country’s data privacy laws, e.g., the European
`Union’s General Data Protection Regulation (GDPR) (EU) 2016/679. The parties agree to meet
`
`PROTOCOL REGARDING DISCOVERY OF ELECTRONICALLY
`STORED INFORMATION AND ORDER
`(Case No. 2:22-cv-01599-KKE) - 2
`
`Davis Wright Tremaine LLP
`LAW OFFICES
`920 Fifth Avenue, Suite 3300
`Seattle, WA 98104-1610
`206.622.3150 main · 206.757.7700 fax
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`Case 2:22-cv-01599-KKE Document 73 Filed 11/20/23 Page 3 of 14
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`and confer before including custodians or data sources subject to such laws in any ESI or other
`discovery request.
`C.
`ESI Discovery Procedures
`1.
`On-site inspection of electronic media. Such an inspection shall not be required
`absent a demonstration by the requesting party of specific need and good cause or by agreement
`of the parties.
`Search methodology. The parties shall timely confer to attempt to reach agreement
`2.
`on appropriate search terms and queries, file type and date restrictions, data sources (including
`custodians), and other appropriate computer- or technology-aided methodologies, before any such
`effort is undertaken. The parties shall continue to cooperate in revising the appropriateness of the
`search methodology.
`a.
`
`Prior to running searches:
`i.
`The producing party shall disclose the data sources (including
`custodians), search terms and queries, any file type and date restrictions, and any other
`methodology that it proposes to use to locate ESI likely to contain responsive and discoverable
`information. The requesting party may request, and the producing party may provide, unique hit
`counts for each search query. To the extent any disputes arise regarding the provision of hit
`counts, the parties shall meet and confer in a good-faith effort to resolve the issue.
`ii.
`After disclosure, the parties will engage in a meet and confer
`process regarding additional terms sought by the non-producing party.
`iii.
`The following provisions apply to search terms/queries of the
`requesting party. Focused terms and queries should be employed; broad terms or queries, such as
`product and company names, generally should be avoided. A conjunctive combination of multiple
`words or phrases (e.g., “computer” and “system”) narrows the search and shall count as a single
`search term. A disjunctive combination of multiple words or phrases (e.g., “computer” or
`“system”) broadens the search, and thus each word or phrase shall count as a separate search term
`unless they are variants of the same word. The producing party may identify each search term or
`Davis Wright Tremaine LLP
`PROTOCOL REGARDING DISCOVERY OF ELECTRONICALLY
`LAW OFFICES
`STORED INFORMATION AND ORDER
`920 Fifth Avenue, Suite 3300
`(Case No. 2:22-cv-01599-KKE) - 3
`Seattle, WA 98104-1610
`206.622.3150 main · 206.757.7700 fax
`
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`Case 2:22-cv-01599-KKE Document 73 Filed 11/20/23 Page 4 of 14
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`query returning overbroad results demonstrating the overbroad results and a counterproposal
`correcting the overbroad search or query. The parties will meet and confer to address concerns
`relating to overbroad search term results.
`Format.1
`3.
`a.
`ESI will be produced to the requesting party with searchable text to the
`extent it exists, in a format to be decided between the parties. The producing party shall include
`the files specified in Exhibit A with each production, to the extent they are reasonably accessible
`and non-privileged.
`Unless otherwise agreed to by the parties, files that are not easily converted
`b.
`to image format, including but not limited to spreadsheet, database, audio, video, and drawing
`files, will be produced in native format.
`c.
`Each document image file shall be named with a unique number (Bates
`Number). Documents produced in native format will be assigned a Bates Number and be
`produced with a corresponding load file. File names should not be more than twenty characters
`long or contain spaces.
`d.
`If a document is more than one page, the unitization of the document and
`any attachments and/or affixed notes shall be maintained as they existed in the original document.
`e.
`The full text of each electronic document shall be extracted (“Extracted
`Text”) and produced in a text file. The Extracted Text shall be provided in searchable ASCII
`text format (or Unicode text format if the text is in a foreign language) and shall be named with
`a unique Bates Number (e.g., the unique Bates Number of the first page of the corresponding
`production version of the document followed by its file extension).
`
`
`1 Documents that are not produced in the first instance in this litigation, i.e., documents that were
`previously produced in other matters, shall be produced pursuant to the ESI protocols governing
`the format of document productions in those other matters, provided that those re-productions are
`in a reasonably useful format and provided that the producing party informs all other parties,
`prior to or at the time of production, that the production will be in a nonconforming format. The
`parties reserve the right to object to a nonconforming format.
`
`PROTOCOL REGARDING DISCOVERY OF ELECTRONICALLY
`STORED INFORMATION AND ORDER
`(Case No. 2:22-cv-01599-KKE) - 4
`
`Davis Wright Tremaine LLP
`LAW OFFICES
`920 Fifth Avenue, Suite 3300
`Seattle, WA 98104-1610
`206.622.3150 main · 206.757.7700 fax
`
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`Case 2:22-cv-01599-KKE Document 73 Filed 11/20/23 Page 5 of 14
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`De-duplication. The parties may de-duplicate their ESI production across custodial
`4.
`and non-custodial data sources after disclosure to the requesting party, and the duplicate custodian
`information removed during the de-duplication process shall be tracked in a custodian field in the
`database load file. If processing and production is done on a rolling basis, an updated duplicate
`custodian field with additional values shall be provided in an overlay. The producing party shall
`identify whether the overlay replaces previously produced fields for a file or supplements them.
`5.
`Email Threading. The parties may use analytics technology to identify email
`threads and need only produce the unique most inclusive copy and related family members and
`may exclude lesser inclusive copies. Upon reasonable request, the producing party will produce
`a less inclusive copy or missing metadata, if, for example, a threaded email cuts off
`to/from/cc/subject line/date information.
`Metadata fields. If the requesting party seeks metadata, the parties agree that only
`6.
`the metadata fields identified in Exhibit B need be produced, and only to the extent they are
`reasonably accessible and non-privileged. The list of metadata included in Exhibit B is intended
`to be flexible and may be changed by agreement of the parties.
`7.
`Databases. Certain types of databases are dynamic in nature and may contain
`information that is neither relevant nor reasonably calculated to lead to the discovery of
`admissible evidence. The parties shall meet and confer regarding whether such databases must
`be produced and the appropriate format for productions from dynamic databases, including as to
`whether the data may be produced in an alternate form, such as a report, data table, or other
`static format. The parties agree to identify the specific databases, by name, that contain the
`relevant and responsive information that parties produce.
`8.
`Hard-Copy Documents. If the parties elect to produce hard-copy documents in an
`electronic format, the production of hard-copy documents will include a cross-reference file that
`indicates document breaks and sets forth the custodian or custodian/location associated with each
`produced document. Hard-copy documents will be scanned using Optical Character Recognition
`technology and searchable ASCII text files will be produced (or Unicode text format if the text is
`Davis Wright Tremaine LLP
`PROTOCOL REGARDING DISCOVERY OF ELECTRONICALLY
`LAW OFFICES
`STORED INFORMATION AND ORDER
`920 Fifth Avenue, Suite 3300
`(Case No. 2:22-cv-01599-KKE) - 5
`Seattle, WA 98104-1610
`206.622.3150 main · 206.757.7700 fax
`
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`Case 2:22-cv-01599-KKE Document 73 Filed 11/20/23 Page 6 of 14
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`in a foreign language), unless the producing party can show that the cost would outweigh the
`usefulness of scanning (for example, when the condition of the paper is not conducive to scanning
`and will not result in accurate or reasonably useable/searchable ESI). Each file will be named
`with a unique Bates Number (e.g., the unique Bates Number of the first page of the corresponding
`production version of the document followed by its file extension).
`D.
`Preservation of ESI
`The parties acknowledge that they have a common law obligation, as expressed in Fed. R.
`Civ. P. 37(e), to take reasonable and proportional steps to preserve relevant and discoverable
`information in the party’s possession, custody, or control. With respect to preservation of ESI,
`the parties agree as follows:
`1.
`Absent a showing of good cause by the requesting party, the parties shall not be
`required to modify the procedures used by them in the ordinary course of business to back up and
`archive data; provided, however, that the parties shall preserve all discoverable ESI in their
`possession, custody, or control.
`2.
`The parties will supplement their initial disclosures in accordance with Fed. R.
`Civ. P. 26(e) with discoverable ESI responsive to a particular discovery request or mandatory
`disclosures where that data is created after a disclosure or response is made (unless excluded
`under Sections D(3) or E(1)-(2)). The parties will meet and confer in good faith regarding a
`reasonable schedule and cut-off date for supplementation.
`3.
`Only unique, non-duplicative sources of relevant documents need to be preserved.
`The parties shall use objective measures to determine whether two sources are duplicative. Where
`documents are possessed by multiple custodians, each custodian’s copy is a unique,
`non-duplicative document.
`4.
`Absent a showing of good cause by the requesting party, the following categories
`of ESI that need not be preserved include:
`a. Deleted, slack, fragmented, or other data only accessible by forensics.
`
`PROTOCOL REGARDING DISCOVERY OF ELECTRONICALLY
`STORED INFORMATION AND ORDER
`(Case No. 2:22-cv-01599-KKE) - 6
`
`Davis Wright Tremaine LLP
`LAW OFFICES
`920 Fifth Avenue, Suite 3300
`Seattle, WA 98104-1610
`206.622.3150 main · 206.757.7700 fax
`
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`Case 2:22-cv-01599-KKE Document 73 Filed 11/20/23 Page 7 of 14
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`b. Random access memory (RAM), temporary files, or other ephemeral data
`that are difficult to preserve without disabling the operating system.
`c. On-line access data such as temporary internet files, history, cache,
`cookies, and the like.
`d. Interim automatically saved drafts, as opposed to drafts saved by a user.
`e. Data in metadata fields that are frequently updated automatically, such as
`last-opened dates (see also Section (E)(5)).
`f. Dynamic fields of databases or log files that are not retained in the usual
`course of business.
`g. Back-up data that are duplicative of data that are more accessible
`elsewhere.
`h. Server, system or network logs.
`i. Data remaining from systems no longer in use that is unintelligible on the
`systems in use.
`j. Electronic data (e.g., email, calendars, contact data, and notes) sent to or
`from mobile devices (e.g., iPhone, iPad, Android devices), provided that a
`copy of all such electronic data is automatically saved in real time
`elsewhere (such as on a server, laptop, desktop computer, or “cloud”
`storage).
`The parties agree to confer in good faith regarding adding other categories to this
`
`5.
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`list.
`E.
`
`Privilege
`1.
`The parties agree to abide by Fed. R. Civ. P. 26(b)(5) with respect to documents
`fully withheld from production on the basis of a privilege or other protection, unless otherwise
`agreed or excepted by this Agreement or Order. Privilege logs shall include a unique identification
`number for each document and the basis for the claim (attorney-client privileged or work-product
`protection). For ESI, the privilege log may be generated using available metadata, including
`Davis Wright Tremaine LLP
`PROTOCOL REGARDING DISCOVERY OF ELECTRONICALLY
`LAW OFFICES
`STORED INFORMATION AND ORDER
`920 Fifth Avenue, Suite 3300
`(Case No. 2:22-cv-01599-KKE) - 7
`Seattle, WA 98104-1610
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`
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`Case 2:22-cv-01599-KKE Document 73 Filed 11/20/23 Page 8 of 14
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`author/recipient or to/from/cc/bcc names; the subject matter or title; and date created. Should the
`available metadata provide insufficient information for the purpose of evaluating the privilege
`claim asserted, the producing party shall include such additional information as required by the
`Federal Rules of Civil Procedure. Privilege logs will be produced no later than 60 days after the
`deadline for substantial completion of document productions. To the extent a party produces
`documents after the deadline for substantial completion, and withholds from such production any
`documents on the basis of privilege, that party shall provide a supplemental privilege log within
`30 days of the production. A document initially included on a privilege log may be produced after
`the close of fact discovery, either by agreement or when the basis for the privilege asserted has
`been successfully challenged by another party.
`2.
`Redactions need not be logged so long as the basis for the redaction is clear on the
`redacted document.
`3.
`With respect to privileged or work-product information generated after the filing
`of the complaint, parties are not required to include any such information in privilege logs.
`4.
`Activities undertaken in compliance with the duty to preserve information are
`protected from disclosure and discovery under Fed. R. Civ. P. 26(b)(3)(A) and (B).
`5.
`Pursuant to Federal Rule of Evidence 502(d) and (e), the production of a privileged
`or work product protected document is not a waiver of privilege or protection from discovery in
`this case or in any other federal or state proceeding. For example, the mere production of a
`privileged or work product protected document in this case as part of a production is not itself a
`waiver. Nothing in this Order 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 documents and ESI. Moreover,
`nothing in this Order shall be interpreted to require disclosure of information subject to privacy
`protections as set forth in law or regulation, including information that may need to be produced
`from outside of the United States and/or may be subject to foreign laws.
`PROTOCOL REGARDING DISCOVERY OF ELECTRONICALLY
`STORED INFORMATION AND ORDER
`(Case No. 2:22-cv-01599-KKE) - 8
`
`Davis Wright Tremaine LLP
`LAW OFFICES
`920 Fifth Avenue, Suite 3300
`Seattle, WA 98104-1610
`206.622.3150 main · 206.757.7700 fax
`
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`Case 2:22-cv-01599-KKE Document 73 Filed 11/20/23 Page 9 of 14
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`F.
`
`Non-Party Discovery
`A party that issues a non-party subpoena (the “Issuing Party”) shall include a
`1.
`copy of this ESI Protocol with the subpoena.
`The Issuing Party shall be responsible for producing any documents obtained
`2.
`under a subpoena to all other parties.
`If the non-party production is not Bates-stamped, the Issuing Party shall endorse
`3.
`the non-party production with unique prefixes and Bates numbers prior to producing them to
`all other parties.
`G.
`Foreign-Language Documents
`All documents shall be produced in their original language. Where a requested document
`exists in a foreign language and the producing party also has an English-language version of
`that document that it prepared for non-litigation purposes prior to filing of the lawsuit, the
`producing party shall produce both the original document and all English-language versions. In
`addition, if the producing party has a certified translation of a foreign-language document that
`is being produced (whether or not the translation is prepared for purposes of litigation), the
`producing party shall produce both the original document and the certified translation. Nothing
`in this Agreement shall require a producing party to prepare a translation, certified or otherwise,
`for foreign-language documents that are produced in discovery.
`
`
`
`PROTOCOL REGARDING DISCOVERY OF ELECTRONICALLY
`STORED INFORMATION AND ORDER
`(Case No. 2:22-cv-01599-KKE) - 9
`
`Davis Wright Tremaine LLP
`LAW OFFICES
`920 Fifth Avenue, Suite 3300
`Seattle, WA 98104-1610
`206.622.3150 main · 206.757.7700 fax
`
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`Case 2:22-cv-01599-KKE Document 73 Filed 11/20/23 Page 10 of 14
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`EXHIBIT A – FILE STRUCTURE
`
`File Structure. The Producing Party shall produce the following sets of files with each
`production.
`
`a.
`
`Image Load File.
`
`(1) Every document referenced in a production image load file must
`have all corresponding images, text and metadata.
`
`(2) The name of the image load file must mirror the name of the
`delivery volume and should have an .OPT file extension.
`
`(3) The volume names must be reasonably consecutive (e.g. ABC001,
`ABC002…).
`
`(4) The load file must contain one line per image.
`
`(5) Every image in the delivery volume must be contained in the
`image load file.
`
`(6) The image key must be named the same as the Bates number of the
`image.
`
`(7) Load files must not span across media.
`
`(8) File should be placed in the root directory or a directory labeled
`“DATA.”
`
`b.
`
`Metadata Load File.
`
`(1)
`
`(2)
`
`(3)
`
`(4)
`
`(5)
`
`(6)
`
`Each production has one load file, in “Concordance” style .DAT
`format.
`
`Values must be enclosed by þ (ASCII Decimal 254).
`
`Values must be separated by the “Device Control 4” character,
`ASCII decimal 20.
`
`First line must contain the column/field names (set forth in Section
`IV, below).
`
`The fields Begin Bates and End Bates must be present, and the first
`fields listed in the load file.
`
`The field NativePath must be present if native files are included in
`the document production.
`
`Each subsequent row must contain the Metadata for one
`(7)
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`Case 2:22-cv-01599-KKE Document 73 Filed 11/20/23 Page 11 of 14
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`Document.
`
`(8)
`
`Every row must have the same number of columns/fields (empty
`values are acceptable).
`
`(9)
`
`Text must be encoded in UTF-8.
`
`(10) File should be placed in the root directory or a directory labeled
`“DATA.”
`
`c.
`
`OCR and Extracted Text Files (.TXT Files).
`
`(1)
`
`(2)
`
`(3)
`
`(4)
`
`(5)
`
`A single text file for each Document containing all the Document’s
`pages, in text.
`
`Pages separated by form feed character (decimal 12, hex 0xC).
`
`Filenames should be of the form: <Bates num>.txt, where <Bates
`num> is the Bates number of the first page of the Document.
`
`Text must be encoded in UTF-8.
`
`Files should be placed in a directory labeled “TEXT.”
`
`d.
`
`Image Files.
`
`(1)
`
`(2)
`
`Document level PDF, slipsheet image, or Single-page Group IV
`TIFF images for each Document, containing all images for that
`document.
`
`Filenames should be of the form: <Bates num>.<ext>, where
`<Bates num> is the BATES number of the first page of the
`document (i.e., the “Begin Bates” number), and <ext> is the
`appropriate extension for the image format (.pdf or .tiff).
`
`(3)
`
`Files should be placed in the “IMAGES” subdirectory.
`
`e.
`
`Native Files.
`
`(1)
`
`(2)
`
`Document level native file for each native file included in the
`document production.
`
`Filenames should be of the form: <Bates num>.<ext>, where
`<Bates num> is the BATES number of the document.
`Confidentiality designations may be included in the filenames,
`after the BATES number.
`
`A relative link to the location of the native file in the document
`(3)
`Davis Wright Tremaine LLP
`PROTOCOL REGARDING DISCOVERY OF ELECTRONICALLY
`LAW OFFICES
`STORED INFORMATION AND ORDER
`920 Fifth Avenue, Suite 3300
`(Case No. 2:22-cv-01599-KKE) - 11
`Seattle, WA 98104-1610
`206.622.3150 main · 206.757.7700 fax
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`Case 2:22-cv-01599-KKE Document 73 Filed 11/20/23 Page 12 of 14
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`
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`productions shall be produced in NATIVEPATH metadata field in
`the .DAT load file.
`
`(4)
`
`Files should be placed in a directory named “NATIVES.”
`
`
`
`PROTOCOL REGARDING DISCOVERY OF ELECTRONICALLY
`STORED INFORMATION AND ORDER
`(Case No. 2:22-cv-01599-KKE) - 12
`
`Davis Wright Tremaine LLP
`LAW OFFICES
`920 Fifth Avenue, Suite 3300
`Seattle, WA 98104-1610
`206.622.3150 main · 206.757.7700 fax
`
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`Case 2:22-cv-01599-KKE Document 73 Filed 11/20/23 Page 13 of 14
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`
`
`EXHIBIT B - METADATA FIELDS
`
`
`For ESI and documents that were originally stored in electronic format, all fields below
`should be provided, to the extent reasonably available. Applicable fields will be provided for
`scanned hard copy documents. The parties acknowledge that not all fields below may be
`reasonably available to all producing parties, and further that a producing party does not violate
`this Order by failing to include in its productions metadata fields that are not reasonably available.
`Unless otherwise agreed by the parties, the field-naming conventions shall be as stated below, and
`shall be consistently applied across all productions:
`
`FIELD NAME
`Begin Bates
`
`End Bates
`
`EndFamily/EndAttach
`
`AttachCount
`AttachNames
`
`Custodian
`
`All Custodians
`
`FIELD DESCRIPTION
`The production Bates number associated with the first page
`of a Document.
`The production Bates number associated with the last page
`of a Document.
`BeginFamily/BeginAttach Begin Bates number of the first page of parent Document
`of family of attachments.
`End Bates number of the last page of last attachment to a
`family of Documents.
`Number of document attachments.
`Native file names of each individual attachment, separated
`by semicolons.
`Identification of the custodian(s) from whom the file was
`sourced.
`Identification of all custodians who the producing party
`agreed to produce and where a duplicate of the Document
`was de-duplicated when processing the documents.
`The file path from which the document was collected
`Identification of all file paths for duplicate copies.
`Author field extracted from the Metadata of a Document or
`other creator identified for the Document.
`From field extracted from the Metadata of an email
`message.
`To field extracted from the Metadata of an email message.
`Cc field extracted from the Metadata of an email message.
`Bcc field extracted from the Metadata of an email message.
`Total number of pages in the Document.
`Datetime received (MM/DD/YYYY HH/MM/SS).
`Datetime sent (MM/DD/YYYY HH/MM/SS).
`Datetime created (MM/DD/YYYY HH/MM/SS).
`Datetime that a Document was last modified
`(MM/DD/YYYY HH/MM/SS).
`Identification of person(s) who last modified a Document.
`Unique Message Id.
`Message ID of email that instant email is in reply to.
`Davis Wright Tremaine LLP
`LAW OFFICES
`920 Fifth Avenue, Suite 3300
`Seattle, WA 98104-1610
`206.622.3150 main · 206.757.7700 fax
`
`File Path
`All Paths
`Author
`
`From
`
`To
`Cc
`Bcc
`Pages
`Date Received
`Date Sent
`Date Created
`Date Modified
`
`Last Modified By
`Message Id
`In Reply To
`
`PROTOCOL REGARDING DISCOVERY OF ELECTRONICALLY
`STORED INFORMATION AND ORDER
`(Case No. 2:22-cv-01599-KKE) - 13
`
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`Case 2:22-cv-01599-KKE Document 73 Filed 11/20/23 Page 14 of 14
`
`
`
`FIELD NAME
`Subject
`
`Filename
`File Extension
`File Size
`MD5 Hash
`SHA1 Hash
`NativePath
`TextPath
`Redacted
`Placeholder
`Confidentiality
`Track Changes
`Hidden Content
`
`Speaker Notes
`Has Comments
`Production Volume
`Producing Party
`
`
`
`
`DATED: November 15, 2023
`
`
`
`
`
`
`
`FIELD DESCRIPTION
`Subject line extracted from an email, e-document or e-
`attachment.
`The full name of the Native File.
`The extension of the file.
`The size of the file in bytes.
`The MD5 hash value of a Document.
`The SHA1 hash value of a Document.
`The relative path to the native file for this Document.
`The relative path to the text file for this Document.
`Whether a Document has redactions (Y/N).
`Whether a Document has a placeholder image (Y/N).
`Level of Confidentiality assigned.
`Document has track changes (Y/N).
`Identifies documents with hidden content (i.e. hidden rows,
`columns, sheets, or slides).
`Document has speaker notes (Y/N).
`Indicates there are comments in the document.
`Production volume number (e.g., V001, V002, etc.).
`Name of party producing the Document.
`
`ORDER
`
`Based on the foregoing, IT IS SO ORDERED.
`
`
`Dated this 20th day of November, 2023.
`
`A
`
`Kymberly K. Evanson
`United States District Judge
`
`
`
`PROTOCOL REGARDING DISCOVERY OF ELECTRONICALLY
`STORED INFORMATION AND ORDER
`(Case No. 2:22-cv-01599-KKE) - 14
`
`Davis Wright Tremaine LLP
`LAW OFFICES
`920 Fifth Avenue, Suite 3300
`Seattle, WA 98104-1610
`206.622.3150 main · 206.757.7700 fax
`
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