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Mensie v. Toyota Motor Credit Corp.

United States District Court, E.D. Arkansas, Western Division

September 25, 2017

MARIAN J. MENSIE, on behalf of herself and on behalf of all others similarly situated, Plaintiff,
v.
TOYOTA MOTOR CREDIT CORP., Defendant.

          PLAINTIFFS: Michael B. Phillips Brandon K. Moffitt Trevor Brent Townsend Robert A. Hom Joseph A. Kronawitter Hom Aylward & Bandy, LLC Brian Timothy Meyers Brian C. McCart Law Offices of Brian Timothy Meyers

          DEFENDANTS: Anna S. McLean (pro hac vice) Joy 0. Siu (pro hac vice) Sheppard, Mullin, Richter & HamptonLLP Four Embarcadero Center Michael D. Barnes (88071) Wright, Lindsey & Jennings LLP Robert L. Jones, III Vicki Bronson Conner & Winters, LLP

          AGREED DOCUMENT PRODUCTION PROTOCOL

         1. Definitions and Scope.

         The following protocol shall control the production of discoverable documents and electronically stored information (collectively, "Documents"). As used in this protocol, the term Document(s) shall have the same meaning as used in the Federal Rules of Civil Procedure. The term "Receiving Party" shall mean the party receiving production of Documents in response to any request for production of document(s) pursuant to Fed.R.Civ.P. 34 or pursuant to initial production of documents identified in the party's Rule 26(a) disclosures. "Producing Party" shall mean the party producing Documents in response to any request for production of documents pursuant to Rule 34 or pursuant to initial production of documents identified in the party's Rule 26(a) disclosures.

         2. General Format of Production.

         Subject to the provisions of paragraph 3, Documents that are produced in these proceedings, whether originally stored in paper or electronic form, shall be produced in electronic image form in the manner as described below.

         3. Production Format.

         Documents shall be produced according to the following formats:

(a) Paper Documents. Documents that are maintained in paper format shall be scanned as black and white images at 300 d.p.i., in a Group 4 compression single-page Tagged Image File Format ("TIFFs" or ".tiff format") and reflect the full and complete information contained in the original Document unless a document is redacted, in which case the Producing Party shall withhold the redacted text for that Document.
(b) Electronically Stored Information. Except as provided in Paragraph 3(d) below, document images from electronic Documents shall be generated in a Group 4 compression single-page "TIFF" image. In the event a Document is redacted, the Producing Party shall withhold the redacted text for that Document. The failure to withhold such text for a redacted document by a Producing Party shall not be deemed a waiver of the privilege associated with that Document.
(c) Resolution of Production Issues. Documents that cannot be read because of imaging or formatting problems shall be promptly identified by the Receiving Party. The Producing Party and the Receiving Party shall meet and confer to attempt to resolve problem(s), to the extent the problem(s) are within the Parties' control.
(d) Native Format Documents. "Native Format Documents" (or "Native Format") are defined as electronic Documents that have an associated file structure defined by the creating application. Notwithstanding the foregoing provisions of this paragraph, the parties recognize that it may be appropriate for certain Documents to be produced in Native Format.
Additionally, the Producing Party reserves the right in the first instance to produce certain files (e.g., spreadsheets) in native format. After receipt of the production, if the Requesting Party believes in good faith that certain documents should be produced in native format, it may request native format production. In that event, the Receiving Party and the Producing Party will meet and confer to discuss alternative production requirements, concerns, formats, methods and/or cost sharing. All redacted documents shall be produced in TIFF format and the Producing Party does not need to produce in Native Format a document that was redacted and produced in TIFF format.
(e) Color. Documents shall be produced in black and white in the first instance. If a produced Document contains color and that color is necessary to decipher the meaning, context, or content of the document, the Producing Party shall honor reasonable requests for either the production of the original Document for inspection and copying or production of a color image of the Document. The Producing Party will pay the cost for the production of a reasonable number of color images to be decided by the Parties after meeting and conferring regarding the same.
(f) Load File Structure. The Producing Party shall produce a unitization file ("load file") for all produced Documents in accordance with the following formatting:
Images:
• .opt file compatible with Concordance and Relativity
• Single page per image
• Single image per file
• TIFF format.
• Images shall be named as follows:
<Bates num>.<ext> Where <Bates num> is the BATES number of the page, and <ext> is the format ...

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