Extract to table

Summary of the Litigation The following is a summary of the key facts and claims at issue in the Action, provided for the purpose of informing custodians about the scope of potentially relevant documents and ESI that must be preserved

Subject Matter Categories All documents and ESI relating to any of the following subject matter categories must be preserved, regardless of the form in which they exist, the medium on which they are stored, or the location at which they are maintained

Each custodian named below must take immediate steps to preserve all materials responsive to the subject matter categories and document types described in Section III above

Immediate Actions Required The following actions must be taken immediately upon receipt of this memorandum: 1

Each custodian must immediately cease any routine or automatic deletion of documents and ESI within the scope described in Section III above

All backup tapes, archives, disaster-recovery systems, and any other backup media containing data from the identified custodians must be preserved and must not be overwritten, recycled, or destroyed