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Abrams v. HBM Prenscia Inc.

United States District Court, S.D. New York

January 14, 2020

SCOTT B. ABRAMS, Plaintiff,
v.
HBM PRENSCIA INC., SPECTRIS INC. and SPECTRIS PLC, Defendants.

          JAMIE M. BRICKELL PRYOR CASHMAN LLP ATTORNEYS FOR PLAINTIFF

          ALAN E. SCHOENFELD ATTORNEYS FOR DEFENDANTS

          JOINT MOTION FOR ENTRY OF ESI PROTOCOL ORDER

          HON. VALERIE E. CAPRONI JUDGE

         The parties in the above-captioned litigation have conferred and have agreed, subject to the Court's approval, to the following plan governing disclosure and discovery of information potentially relevant to this litigation, including electronically stored information ("ESI"), paper documents, data, and other information (together, "Information").

         This Stipulation and [Proposed] Order ("Stipulated Order") will govern discovery in this litigation, including search, disclosure, and production, of potentially relevant Information. Each party reserves the right to seek exceptions, amendments, or modifications to this Stipulated Order by mutual agreement and/or from the Court, and this Stipulated Order shall not be binding on any party once it is dismissed from these proceedings.

         A. Cooperation

         1. The parties will cooperate in good faith regarding all discovery matters and will seek to resolve any disputes through meet and confers as such disputes may arise. The parties each agree to respond reasonably and in good faith to another party's inquiry regarding any discovery matter, and to endeavor to provide an understanding of any efforts taken to comply with any discovery request so that the parties may have an informed and productive meet and corner tor the purpose of addressing any concerns.

         2. This Stipulated Order shall be interpreted in a manner consistent with the parties' rights and obligations under any Federal, Local, or Court rule and any Order of this Court, Each producing party reserves all rights to interpose all appropriate objections to all document requests and other discovery requests.

         3. The parties agree to take the proportionality considerations addressed in Fed.R.Civ.P. 26(b)(1) into account in the conduct of discovery in this matter. Adopting a tiered or sequenced approach to discovery may be appropriate in order to facilitate future targeted discovery and production from more readily accessible sources of information. The parties agree to continue to consider and confer about the most efficient and cost-effective processes as discovery proceeds.

         B. Exchange of Discovery Materials

         1. Within 30 days of the parties serving their initial disclosures they shall meet and confer in good faith to reach an agreement on methods to be used in searching for or otherwise identifying responsive documents and ESI. This discussion may include, as necessary, identifying custodians, custodial and non-custodial sources of documents, date ranges, file types, or any other proposed method (e.g. search terms, or technology aided methodology).

         2. The parties shall regularly meet and confer regarding the methods they intend to use or are using as part of the search and filtering process in discovery. Such meet and confers shall include such disclosures that will provide the requesting party sufficient information to understand the process the producing party is employing and to allow the parties to judge the efficacy of such efforts.

         3. If a producing party elects to use technology assisted review ("TAR"), it shall meet and confer in good faith regarding the TAR methods it intends to use or are using as part of the search and filtering process in discovery. Such meet and confers shall include such disclosures that will provide the requesting party sufficient information to understand the process the producing party is employing and to allow the parties to judge the efficacy and reliability of such efforts.

         4. In the absence of agreement on appropriate search terms, or an appropriate TAR methodology, the ...


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