In the case of personal database (e.g., MS Access) files containing confidential or privileged information, the Producing and Requesting Parties shall meet and confer to determine the appropriate form of production.

Attachments: If an attachment is unrelated to CUSIPs or the claims and defenses in this litigation, and is not otherwise independently responsive to a Party’s document requests, it may be withheld if it (i) contains only highly sensitive personal information, such as a family photo or personal medical records; or (ii) if it is Highly Confidential Material (as defined in the Stipulated Protective Order or any amendment thereto) that falls entirely into one of the specifically enumerated categories of information set forth in Section II.M.3 or that are otherwise agreed by the Parties or ordered by the Court.

Unitization: Where the documents were organized into groups, such as folders, clipped bundles, and binders, this structure shall be maintained and provided in the Load File to the extent reasonably practicable.

If redacting TIFF images, the Producing Party shall make reasonable efforts to (1) reveal hidden rows, columns, or sheets prior to converting the document to TIFF; (2) clear any filters that may conceal information; (3) adjust column widths so that numbers do not appear as “########”; (4) ensure that column and row headings print; (5) ensure that the tab name appears in the header or footer of the document; (6) process comments so that they are produced at the end of the spreadsheet; (7) process spreadsheets so that they print across and then down; and (8) process presentations (such as PowerPoints) so that all speaker notes and comments are visible.

If the items redacted and partially withheld from production are audio/visual files, the Producing Party shall, to the extent reasonably practicable, provide the unredacted portions of the content.

The term “Party” means a plaintiff or defendant in this Litigation, including the officers, directors, principals, employees, consultants, and outside counsel acting on behalf of a corporate party.

“Parties” means any combination of plaintiffs or defendants in this Litigation, including the officers, directors, principals, employees, consultants, and outside counsel acting on behalf of corporate parties.

Persons or entities that provide litigation support services of any type (including, but not limited to photocopying, videotaping, preparing exhibits or demonstrations, and organizing, storing, or retrieving data in any form or medium) their employees and subcontractors.

The Parties (and Non-Parties, to the extent applicable) shall meet and confer within 14 days to discuss the objection and make a good faith effort to resolve any dispute by agreement or stipulation.

A person whom the Highly Confidential Material itself indicates, or the Receiving Party otherwise has a good-faith basis to believe, was the author, creator, producer, addressee, source, custodian or recipient of the document;