Extract to table

The Parties expressly reserve the right to seek modification of this Stipulation and the resulting Protective Order upon a showing of good cause, whether to expand or restrict the protections afforded hereunder, and nothing in this Stipulation shall be construed to preclude any Party from seeking such relief from the Court at any time during the pendency of this action

As used in this Stipulation and in any Protective Order entered by the Court incorporating these terms, the following terms shall have the meanings set forth below: 1

The Party asserting that any of the foregoing exclusions applies shall bear the burden of establishing the applicability of the exclusion

For documents produced in hard copy, the designation shall appear on each page of the document

For ESI produced in electronic format, the designation shall be applied, as appropriate, to load file fields, objective coding fields, Bates-stamped images, metadata fields, or cover pages accompanying the production

The designating Party shall identify on the record, with reasonable specificity, the portions of testimony to be designated and the level of designation applicable to each such portion