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Huff v. CoreCivic, Inc.
United States District Court, D. Kansas
September 26, 2017
Ashley Huff and Gregory Rapp, individually and on behalf of all others similarly situated, Plaintiffs,
CoreCivic, Inc., f/k/a Corrections Corporation of America, et al. Defendants.
AGREED DOCUMENT PRODUCTION PROTOCOL
P. O'Hara U.S. Magistrate Judge
Definitions and Scope.
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.
General Format of Production.
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.
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 and provide OCR
for the redacted 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
(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
(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
. .opt file compatible with Concordance and
Relativity . Single page per image
. Single image per file .
. 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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