Extract to table

The parties stipulate and agree that this ESI protocol shall govern the discovery of electronically stored information in both this action and the Halloran Action, and shall become binding on all parties to the Halloran Action upon entry of the anticipated Consolidation Order

Nothing in this Stipulation shall be construed to alter, amend, or supersede the Confidentiality Protective Order

DEFINITIONS As used in this Stipulation and [Proposed] Order, the following terms shall have the meanings set forth below

These definitions are provided for convenience and clarity; to the extent any term used in this Stipulation is not defined herein, it shall be given its ordinary meaning in the context of electronic discovery

Load files may take the form of concordance DAT files, Relativity load files, EDRM XML files, or other industry-standard formats, and shall conform to the specifications agreed upon by the parties as set forth in Section IV of this Stipulation

The privilege log shall contain sufficient information to enable the Receiving Party to assess the validity of the privilege claim without disclosing the privileged content itself