(Model) Stipulated Order For Discovery Of Electronically Stored Information (Judge Harjani)

[MODEL] STIPULATED ORDER FOR DISCOVERY OF ELECTRONICALLY STORED INFORMATION FOR STANDARD LITIGATION. This form issued by Judge Sunil R. Harjani of the U.S. District Court for the Northern District of Illinois, establishes standardized procedures for managing ESI discovery in federal litigation. It supplements the Federal Rules of Civil Procedure and emphasizes cooperation between parties as outlined in the Court’s ESI Guidelines. The order covers key topics including the designation of ESI liaisons, proportional and reasonable preservation obligations, identification of accessible and inaccessible data sources under Rule 26(b)(2)(B), and procedures for search methods, keyword exchange, and metadata production. It allows for phased discovery, specifies acceptable production formats (PDF, TIFF, native, or paper), and provides Rule 502(d) protection against privilege waiver for inadvertent production. The order may be modified by motion for good cause. www.FormsWorkflow.com