(Model) Joint Electronic Discovery Submission Proposed Order (Mag. Judge Reznik)

JOINT ELECTRONIC DISCOVERY SUBMISSION AND PROPOSED ORDER (VICTORIA REZNIK United States Magistrate Judge). This form used in litigation before the United States District Court for the Southern District of New York to establish protocols for handling electronically stored information (ESI) during the discovery process. It ensures that parties manage ESI efficiently, transparently, and in compliance with legal standards. This order is particularly useful when relevant evidence exists in digital formats such as emails, databases, social media, or cloud storage. The document outlines key discovery considerations, including data preservation, search methodologies, production formats, and cost-sharing agreements. It requires attorneys to certify their competence in e-discovery matters and mandates a Rule 26(f) meet-and-confer conference, where parties discuss ESI-related issues like scope of discovery, privilege protection, inadvertent disclosures (claw-back agreements), and potential cost-saving measures. The order also details whether court intervention is needed to resolve disputes over ESI preservation, search techniques, or production. The document sets forth procedures for handling confidential or privileged material under Federal Rule of Evidence 502(d) and establishes guidelines for scheduling further meet-and-confer conferences and court updates on discovery progress. www.FormsWorkflow.com