United States District Court, W.D. Arkansas
CITY OF PONTIAC GENERAL EMPLOYEES' RETIREMENT SYSTEM, Individually and on Behalf of All Others Similarly Situated, Plaintiff,
WAL-MART STORES, INC., et al., Defendants.
ROBBINS GELLER RUDMAN & DOWD LLP JASON A. FORGE DEBRA J.
WYMAN LAURA M. ANDRACCHIO AUSTIN P. BRANE MICHAEL ALBERT,
AUSTIN P. BRANE, Lead Counsel for Plaintiff
TIDWELL & CULBERTSON, LLP, NICHOLAS H. PATTON, GEOFFREY
P. CULBERTSON, Liaison Counsel
BARRETT JOHNSTON MARTIN & GARRISON, LLC DOUGLAS S.
JOHNSTON, JR. TIMOTHY L. MILES, Additional Counsel for
ASKEW III (Ark. Bar No. 86005) TERESA WASTELAND (Ark. Bar No.
81168) KUTAK ROCK LLP, JESS ASKEW III
A. WALD BRIAN T. GLENNON COLLEEN C. SMITH SARAH A. GREENFIELD
NICHOLAS J. SICJLIANO ANDREW R. GRAY MARCY C. PRIEDEMAN
LATHAM AND WATKINS LLP, Attorneys for Defendants Wal-Mart
Stores, Inc. and Michael T. Duke
STIPULATED ORDER ESTABLISHING PROTOCOL FOR PRODUCTION
HONORABLE SUSAN O. HICKEY, UNITED STATES DISTRICT JUDGE
general procedures and protocols outlined herein govern the
search for, review and production of documents, including ESI
(as defined below), by a party during the pendency of this
used in this order, the terms "ESI" or
"Electronically Stored Information" mean "[a]s
referenced in the United States Federal Rules of Civil
Procedure, information that is stored electronically,
regardless of the media or whether it is in the original
format in which it was created, as opposed to stored in hard
copy." The Sedona Conference Glossary.
IDENTIFICATION OF RESPONSIVE DOCUMENTS
and ESI which are neither privileged nor otherwise protected
shall be timely reviewed and produced in accordance with this
Order. After receiving requests for production of documents,
the party making the production (the "Producing
Party") shall conduct a reasonable and good faith search
for responsive documents.
with the parties' obligations under Rule 26(f)(2) and the
parties' Joint Report pursuant to Fed.R.Civ.P. 26(f) and
Local Rule 26.1 (Dkt. No. 171), both parties have taken
reasonable measures to preserve potentially discoverable data
from alteration or destruction in the ordinary course of
business or otherwise.