(Model) Stipulated Order For Discovery Of Electronically Stored Information (Mag. Judge Hotaling)

[MODEL] STIPULATED ORDER FOR DISCOVERY OF ELECTRONICALLY STORED INFORMATION FOR STANDARD LITIGATION. This form issued by Magistrate Judge Keri Holleb Hotaling of the U.S. District Court for the Northern District of Illinois sets forth standardized procedures for managing ESI discovery in federal cases. This order supplements the Federal Rules of Civil Procedure and emphasizes good-faith cooperation between parties, consistent with the court’s Guidelines for the Discovery of ESI. It covers essential topics including ESI liaisons, proportional preservation limits, designation of accessible versus non-accessible data sources under Rule 26(b)(2)(B), search methodologies (keywords, Boolean logic, metadata), and acceptable production formats (PDF, TIFF, native, or paper). The order also includes Rule 502(d) protection against privilege waiver for inadvertent disclosures and allows modification upon motion for good cause. www.FormsWorkflow.com