IN THE UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

Spume.IO LTD,

Plaintiff

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v.

Atlantic International Capital LLC, d/b/a AIC 

Digital Assets Group,

Defendant.

CASE NO. 9:22-cv-81534

ORDER ESTABLISHING THE PROTOCOL FOR THE PRODUCTION OF 

ELECTRONICALLY STORED INFORMATION

Pursuant to the agreement reached between Plaintiff and Defendant herein, this Court 

adopts and orders the following Protocol relating to the Production of Documents and 

Electronically Stored Information (“ESI”) in the above-captioned Action, which binds all parties 

and their counsel of record in this Action (the “Parties”).

I. SCOPE

The procedures and protocols outlined herein govern the production of documents and ESI 

by all Parties. The Parties will take reasonable steps to comply with this agreed-upon protocol for 

the Production of Documents and Electronically Stored Information (“Protocol”). All Productions 

made pursuant to this Protocol are subject to any protective order entered in this Action. Nothing 

in this Protocol is intended to be an exhaustive list of discovery obligations or rights of a Producing 

Party or Requesting Party. To the extent additional obligations or rights not addressed in this 

Protocol arise under the Federal Rules of Civil Procedure, Local Rules, or applicable state and 

federal statutes, they shall be controlling. Nothing in this stipulation is intended to alter the parties’ 

rights, obligations, or responsibilities under Federal Rules of Civil Procedure 26(b)(2)(B), 

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34(a)(1), and 37. No provision of this ESI Protocol waives any objections as to the production, 

discoverability, admissibility, or confidentiality of Documents and ESI. The discovery requests, 

objections thereto, agreements, and any pertinent Court orders shall govern the scope of 

Documents and ESI to be produced.

A. Limitations and Non-Waiver 

The Parties and their attorneys do not intend by this Protocol to waive their rights to any 

protection or privilege arising under the laws of any jurisdiction, including the attorney-client 

privilege and the work- product doctrine. All Parties preserve all such privileges and protections, 

and all parties reserve the right to object to any such privileges and protections, including but not 

limited to the attorney-client privilege and the work-product doctrine. The Parties and their 

attorneys are not waiving, and specifically reserve, the right to object to any discovery request on 

any grounds. Further, nothing in this Protocol shall be construed to affect the admissibility of 

documents and ESI. All objections to the discoverability or admissibility of any documents and 

ESI are preserved and may be asserted at any time.

B. Modifications by Agreement

Any practice or procedure set forth herein may be modified by agreement of affected 

Parties, provided that modification has been confirmed in a writing signed by all affected Parties 

or their respective counsel of record. Any Party added or joined to any complaint in this Action 

and any Party to actions that may be consolidated into or coordinated with the above-captioned 

matter after the date of this Protocol that seeks to deviate from the Protocol must obtain leave of 

Court to do so unless all affected Parties otherwise consent in a writing signed by all affected 

Parties or their respective counsel of record.

C. Modification by Court Order

Nothing in this Protocol shall be construed as a waiver of the right of any Party to apply to 

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the Court for an Order modifying its terms for good cause shown, provided, however, that counsel 

for such Party must first meet and confer with the counsel for the opposing Party and the affected 

Parties shall use reasonable best efforts to negotiate an exception from or modification to this 

Agreement and Order prior to seeking relief from the Court.

II. DEFINITIONS

1. “Action” means the above-captioned matter, and any and all cases consolidated or 

coordinated with it. 

2. “Custodian” shall mean any individual of a Producing Party having possession, custody, 

or control of potentially relevant information, Documents, or ESI.

3. “Document” and “Electronically Stored Information” (“ESI”) shall have the same 

meaning as the usage of these terms in Federal Rule of Civil Procedure 34(a)(l)(A).

4. “Email” refers to electronic means for sending, receiving, and managing communications 

via different structured data applications (email client software), including, but not 

limited to, Microsoft Outlook, Google Gmail, Yahoo Mail, or Lotus Notes, and the files 

created or received by such means, though the inclusion of any platform, program, client, 

or software as an example herein will not obligate any Party to collect such ESI.

5. “Instant Messages” means communications involving immediate correspondence 

between two or more users sent via chat client or short message service (SMS), including 

but not limited to, Telegram, WhatsApp, Bloomberg Chat, Google Talk, Yahoo! 

Messenger, AOL Instant Messenger, Blackberry Messenger, ICQ, Pidgin, Line, Audium, 

Trillian, SnapChat or any instant messaging system, though the inclusion of any platform, 

program, client, or software as an example herein will not obligate any Party to preserve 

or collect such ESI.

6. “Load File” means an electronic file containing information identifying a set of paperscanned images or processed ESI and indicating where individual pages or files belong 

together as documents, including attachments, and where each document begins and 

ends. A Load File will also contain data relevant to the individual documents, including 

extracted and user-created Metadata, as well as OCR or Extracted Text, should such data 

be available.

7. “Media” means an object or device, including but not limited to, a disc, tape, computer, 

or other device, on which data is or was stored.

8. “Metadata” means (i) information associated with or about a file that is not ordinarily

viewable or printable from the application that generated, edited, or modified such native 

file which describes the characteristics, origins, or usage or validity of the electronic file; 

and (ii) information generated automatically by the operation of a computer or other 

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technology system when a native file is created, modified, transmitted, deleted, saved, or 

otherwise manipulated by a user of such system.

9. “Native File(s)/Native Format” means and refers to the file structure of a document 

created by the original creating application (in contrast to a Static Image, which is a 

representation of ESI produced by converting a native file into a standard image format 

capable of being viewed and printed on standard computer systems, such as .tiff or .pdf).

10. “OCR” means optical character recognition technology that is capable of reading textbased paper documents or electronic images of documents and making such documents 

searchable using appropriate software.

11. “Producing Party” means any Party or third-Party in the Action that produces documents 

or ESI.

12. “Search Term(s)” means a word or combination of words and phrases designed to capture 

potentially relevant ESI within agreed upon date limitations, if any, and includes strings 

of words and phrases joined by proximity and Boolean connectors.

13. “Static Image” means or refers to a representation of ESI produced by converting a native 

file into a standard image format capable of being viewed and printed on standard 

computer systems. A Tagged Image File Format (TIFF) image is an example of a Static

Image.

14. Reservation of Rights: For the avoidance of doubt, the inclusion of any platform, 

program, application, or software in the preceding paragraphs is merely by way of 

example and does not create any independent obligation or commitment to preserve or 

collect ESI from such platform, program, application, or software. The Parties reserve all 

rights to object to any demand to collect or produce ESI from any or all of the examples 

listed above.

III. IDENTIFICATION OF RESPONSIVE DOCUMENTS AND ESI

Prior to conducting searches for responsive Documents and ESI, the Parties shall meet and 

confer in good faith to reach an agreement on methods to be used to search for or otherwise identify 

responsive Documents and ESI. This discussion may include, as necessary, identifying custodians, 

custodial and non-custodial sources of Documents, date ranges, file types, or any other proposed 

method (e.g., Search Terms). Nothing in this section is meant to suggest that use of any particular 

methodology or Search Terms relieves parties of obligations to produce responsive documents 

under the Federal Rules of Civil Procedure. Further, nothing in this section shall limit a Party's 

right to reasonably seek agreement from the other Parties or a Court ruling to modify previously 

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agreed-upon Search Terms or other search parameters at any time prior to the completion of 

discovery. The Parties will not seek Court intervention with respect to means for identifying 

potentially responsive documents without first attempting to resolve any disagreements in good 

faith via a meet and confer, based upon all reasonably available information.

IV. METHOD OF PRODUCTION OF DOCUMENTS

Producing Party shall, to the extent reasonably and technically possible, produce 

Documents and ESI according to the specifications provided in Appendix A. 

V. PRODUCTION FORMAT FOR DOCUMENTS ORIGINATING AS PAPER 

The following production specifications apply to documents that existed in paper format 

prior to production (i.e., “hard copy documents”). The Parties agree that as a default practice, 

documents will generally be scanned and produced electronically in an appropriately formatted 

file (including OCR) that ensures its accessibility. The Parties agree to generally produce hard 

copy documents in the formats described below, to the extent reasonably practicable and not 

unduly burdensome. These formats are deemed to be productions in reasonably usable form. If a 

Producing Party intends to produce any hard copy documents in any manner other than as specified 

herein, the Producing Party shall notify the Requesting Party of its intent, including production 

format (e.g., produced as paper, made available for inspection). If the proposed production format 

is not acceptable to the Requesting Party, the Parties shall meet and confer to determine a mutually 

acceptable production format for such documents.

A. TIFFs

Documents should be produced as single-page, colored, group IV TIFFs imaged at 300 dpi. 

Bates numbers, confidentiality designations (in accordance with the protective order governing the 

case), and redactions (to the extent they are necessary) should be burned into the image. TIFF 

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image files should be provided in an “Images” folder. 

B. Unitization

Distinct documents should not be merged into a single record, and single documents should 

not be split into multiple records (i.e., paper documents should be logically unitized). For example, 

documents stored in a binder, folder, or similar container (each a “container”) should be produced 

in the same order as they appear in the container. The front cover of the container should be 

produced immediately before the first document in the container. The back cover of the container 

should be produced immediately after the last document in the container. The Parties will 

undertake reasonable efforts to, or have their vendors undertake reasonable efforts to, logically 

unitize documents correctly, and will meet and confer regarding improperly unitized documents.

C. Parent-Child Relationships

The Parties agree that if any part of a document or its attachments is responsive, the entire 

document and attachments will be produced, except any attachments that must be withheld or 

redacted on the basis of any protection or privilege. Any attachments withheld or redacted will be 

logged in accordance with any agreement reached on the format of privilege logs. With respect to 

ESI, the Parties shall take reasonable steps to ensure that parent-child relationships within a 

document family (the association between an attachment and its parent document) are preserved 

and that such child-document(s) should be consecutively produced immediately after the parentdocument. Each document shall be produced with the production number for the first and last page 

of that document in the “BeginBates” and “EndBates” fields of the data load file and with the 

“BegAttach” and “EndAttach” fields listing the production number for the first and last page in 

the document family.

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D. OCR

To the extent that documents that exist in paper or hard copy format have been run through 

optical character recognition (“OCR”) software, the full text shall be provided on a page-level 

basis in an appropriately formatted text file (.txt) that is named to match the first Bates number of 

the document. Text files should be provided in a “Text” folder. To the extent that a document is 

redacted, the text files should not contain the text of the redacted portions. Nothing in this Protocol 

shall create an obligation to correct, supplement, or manually generate text that fails to render 

through reasonable OCR processes.

E. Unique IDs

Each TIFF image should have a unique filename, which corresponds to the Bates number 

of that page. The filename should not contain any blank spaces and should be zero-padded (e.g., 

ABC-000001), taking into consideration the estimated number of pages to be produced. If a Bates 

number or set of Bates numbers is skipped in a production, the Producing Party will so note in a 

cover letter or production log accompanying the production. Bates numbers will be unique across 

the entire production and prefixes will be consistent across all documents a Party produces in the 

Action.

F. Load Files

Documents should be produced in accordance with the specifications in Appendix A. 

G. Metadata

Each of the Metadata and coding fields set forth in Appendix A shall be produced for each 

document where available.

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VI. PRODUCTION FORMAT FOR UNSTRUCTURED ELECTRONICALLY 

STORED INFORMATION

The Parties agree to produce in the formats described below.

A. TIFFS

Documents should be produced as single-page, colored, group IV TIFFs imaged at 300 dpi. 

The document's original orientation should be maintained (i.e., portrait-to-portrait and landscapeto-landscape) to the extent reasonably and technically possible. Where documents are not 

otherwise produced natively, all TIFF images shall display tracked changes, comments and other 

rich data as displayed in the document, regardless of the display setting for this information as last 

saved by the custodian, to the extent reasonably and technically possible. Bates numbers, 

confidentiality designations and redactions (to the extent they are necessary) should be burned into 

the image. TIFF image files should be provided in an “Images” folder.

B. Chat Data 

ESI that is chat or Instant Message data may be produced in TIFF image format, along with 

an image load file and metadata load file, containing the following fields where available:

1. RoomID /PCHAT Number/INTMSGID;

2. Conversation start date and time;

3. Conversation end date and time;

4. Invites;

5. Participants Entered;

6. Participants Left;

7. History Users;

8. Chat Posters;

9. Duration of chat;

10. Participant Count/ Number of Participants; and

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11. Audit.txt

If such chat or Instant Message data poses problems of accessibility, readability or use in 

TIFF form, or if the chat data that existed at the time this Action was filed was not maintained in 

an accessible format at the time of filing, the Parties shall meet and confer to determine the best 

ESI production format, including potentially producing chat files in native format.

C. Unique IDs

Each image should have a unique filename, which corresponds to the Bates number of that 

page. The filename should not contain any blank spaces and should be zero-padded (e.g., ABC000001), taking into consideration the estimated number of pages to be produced. If a Bates 

number or set of Bates numbers is skipped in a production, the Producing Party will so note in a 

cover letter or production log accompanying the production. Bates 000001), taking into 

consideration the estimated number of pages to be produced. If a Bates number or set of Bates 

numbers is skipped in a production, the Producing Party will so note in a cover letter or production 

log accompanying the production. Bates numbers will be unique across the entire production and 

prefixes will be consistent across all documents a Party produces in this Action.

D. Parent-Child Relationships

The Parties agree that if any part of an Email or its attachments is responsive, the entire 

Email and attachments will be produced, except any attachments that must be withheld or redacted 

on the basis of privilege or work-product protection. The relationship between attachments, 

enclosures, embedded files, and/or exhibits to any parent document shall be preserved. The childdocument should be consecutively produced immediately after the parent-document. Each 

document shall be produced with the production number for the first and last page of that document 

in the “BeginBates” and “EndBates” fields of the data load file and with the “BegAttach” and 

“EndAttach” fields listing the production number for the first and last page in the document family.

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E. Metadata

The Parties agree that Metadata will be produced for all ESI, whether produced in Native 

Format or Static Image formats. Appendix A sets forth the minimum metadata fields that must be 

produced to the extent that metadata exists for a particular document. A Party has no obligation 

to manually populate metadata fields.

F. Native Files

1. The processed native file for all spreadsheets (i.e., MS Excel, .CSV, or similar), 

database files (i.e., MS Access), presentation files (i.e., PowerPoint), and electronic information 

containing audio or video components should be produced and linked to the database by the 

metadata field “NativeLink.” These documents should be produced in native format where 

available. For documents that require redactions or other exceptional treatment, the documents 

may be produced in TIFF image form, as long as they remain readable and accessible including 

all hidden information (e.g., redlines) or may be produced with redactions applied directly to the 

native file. 

2. To the extent that a native spreadsheet must be redacted, the Producing Party may 

redact either the native file or produce TIFF images with burned in redactions in lieu of a Native 

File and TIFF placeholder image. If redacting TIFF images and to the extent that any of the 

following can be automated, the Producing Party, or its e-discovery vendor, should make 

reasonable efforts to: (1) reveal hidden rows, columns, or sheets prior to converting the document 

to TIFF; (2) clear any filters that may conceal information; (3) adjust column widths so that 

numbers do not appear as “########”; (4) ensure that column and row headings print; (5) ensure 

that the tab name appears in the header or footer of the document; (6) process comments so that

they are produced at the end of the spreadsheet; and (7) process spreadsheets so that they print 

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across, then down. If good cause exists, the requesting party may ask the Producing Party to 

manually undertake the foregoing for certain documents identified by Bates number by the 

requesting party to the extent the document was originally produced with concealed information. 

The Producing Party shall not unreasonably deny such a request.

3. For Bates-numbered productions only, an endorsed slip sheet should be provided 

with the native file to enable linking to that file within a database. The name of the native file 

should match the Begin Bates number of the slipsheet. The slipsheet should also contain 

“Document Produced Natively” in the center of page, along with the original file name of that 

native file.

4. Other than as specifically set forth herein, a Producing Party need not produce 

documents in Native Format. If good cause exists for the requesting party to request production of 

certain documents in Native Format, the requesting party may request production in Native Format 

by providing (1) a list of the Bates numbers of documents it requests to be produced in Native 

Format; and (2) an explanation of the need for reviewing such documents in Native Format. The 

Producing Party shall not unreasonably deny such requests. The Parties shall meet and confer in 

good faith regarding any disagreement about a request for production of a document in Native 

Format. The Producing Party shall produce an overlay to ensure that the “NativeLink” entry in the 

data load file indicates the relative file path to each Native File in such production, and all 

Extracted Text and applicable metadata fields.

G. Track Changes and Comments

To the extent that a document or ESI not previously processed contains tracked changes or 

comments, the document or ESI should be imaged showing tracked changes and comments to the 

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extent it is not unduly burdensome to do so.

H. Password Protected Files

The Parties will make reasonable efforts to ensure that all encrypted or password-protected 

documents and ESI are successfully processed for review and production. To the extent encrypted 

or password-protected documents are successfully processed, the Parties have no duty to identify 

further the prior encrypted status of such documents. To the extent such Documents are not 

successfully processed despite use of reasonable efforts, including reasonable efforts to obtain 

passwords, a placeholder TIFF image and any available metadata may be produced in place of 

each such Document indicating that security protection could not be removed. On request from 

the Receiving Party, the Parties shall meet and confer in good faith regarding reasonable efforts or 

mechanisms to remove such security protection.

I. Embedded Documents

Embedded files in responsive documents shall be extracted during processing and produced 

as separate documents, with the exception of PNG files or GIF files extracted from signature lines. 

The Bates number of the source file from which the embedded file is extracted shall be provided 

as metadata associated with the embedded file, as described in Appendix A.

J. Deduplication

A Producing Party shall globally deduplicate by exact duplicate families provided that (i) 

only exact (bit-by-bit) duplicates are subject to deduplication; (ii) the Producing Party identifies 

the additional custodians in an All Custodian metadata field; (iii) an Email that includes content in 

the BCC or other blind copy fields shall not be treated as a duplicate of an Email that does not 

include content in the BCC or other blind copy field, even if all remaining content in the email is 

identical, and (iv) notwithstanding anything to the contrary herein, a Producing Party shall produce 

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all attachments regardless of their duplicate status from all emails produced. Further, the Parties 

shall meet and confer in good faith concerning deduplication beyond exact duplicates. If the 

requesting party objects to any deduplication methodology proposed by a Producing Party, it shall 

timely raise those concerns with the Producing Party.

K. Production of Audio and Video Recordings

If audio and/or video recordings are responsive, the Parties should meet and confer to 

determine a mutually agreeable format for producing the audio and/or video recording and/or, to 

the extent a Producing Party objects to producing responsive audio and video recordings on 

grounds of undue burden, regarding the basis for the claim of undue burden. Additionally, the call 

information (metadata) related to each audio recording must be produced and must include, at a 

minimum where available, the following fields:

1. CALLER NAME or CALLER ID: Caller’s name or identification 

number.

2. CALLING NUMBER: Caller’s phone number.

3. FILENAME: Filename of audio file.

4. DATE: Date of call.

5. TIME: Time of call.

6. CALLED PARTY: Name of the party called.

7. CALLED NUMBER: Called party’s phone number.

The filename is used to link the metadata to the produced audio file. The file name in the 

metadata and the file name used to identify the corresponding audio file must match exactly. The 

metadata file must be produced in delimited text format. Field names must be included in the first 

row of the text file.

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L. Custodian or Originating source 

The custodian or originating source shall be identified in the Custodian field of the database 

load files. Documents found in the possession of a natural person (or on a natural person's hardware 

or storage media) should be produced in such fashion as to identify the natural person. Documents 

found in the possession of a department, group, entity, or other common facility (e.g., office, file 

room, archive, network storage, file share, back-up, hard drive, etc.) should be produced in such a 

fashion as to identify the department, group, entity, or facility, when reasonably available. A 

Producing Party shall use a uniform description of a particular custodian across productions.

M. Date Format

1. Dates and times shall be reported in separate fields, with formats of 

MM/DD/YYYY and HH:MM:SSrespectively.

2. Date delimiters, such as slashes and colons, must be consistent 

across all fields. In the format of MM/DD/YYYY, there are no 

spaces and only forward slashes.

3. Date formats must be consistent within any one field.

4. Date formats must be consistent across all fields, i.e., a record with a 

sent date should have the same format in the last modified date field.

5. To the extent reasonably practicable, each Producing Party shall 

process its ESI within a uniform time zone: i.e., Greenwich Mean 

Time “GMT,” Eastern Standard Time “EST.” To the extent a 

Producing Party cannot process ESI with that uniform time zone, it 

shall disclose the same and the Parties shall meet and confer 

regarding a reasonable alternative, such as providing the applicable 

time zone. However, a Producing Party shall have no obligation to 

reformat or otherwise modify date or time data in ESI (e.g., 

spreadsheets, databases or audiofiles).

N. Production Media

The preferred means of producing documents is via secure FTP or secure file share. 

However, documents may also be produced via CD, DVD, flash drive, or hard drive. To the extent 

possible, physical media should be protected before it is produced.

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O. Replacement Productions

Any replacement production will be transmitted with a cover letter or email to identify the 

production as a replacement and cross-reference the BeginBates and EndBates of the documents 

being replaced. If the replacement production is being transmitted by physical media, the media 

shall include the phrase “Replacement Production.”

P. Encrypted Data

To the extent a production is encrypted before it is produced, the Producing Party shall 

contemporaneously transmit the credentials necessary to decrypt the data.

VII. ASSERTIONS OF PRIVILEGE

Privilege Logs shall be provided in a form consistent with Federal Rules of Civil Procedure 

26(b)(5)(A).

VIII. AUTHENTICATION

The Parties will meet and confer regarding an authentication stipulation concerning 

documents and ESI produced in this Action.

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APPENDIX A

Format for both Plaintiff and Defendant productions:

OCR and Extracted Text Files (.TXT Files):

 Single text file per document containing all the document’s pages

 Filenames should be of the form:

<Bates num>.txt

Where <Bates num> is the BATES number of the first page in the 

document.

 Text must be encoded in UTF-8.

Images Files:

 Single page per image

 Single image per file

 TIFF is default FORMAT unless the following formats are agreed to: jpeg, 

jpeg2000, giff, png, single image tiff, and bmp

 Filenames should be of the form:

<Bates num>.<ext>

Where <Bates num> is the BATES number of the page, and <ext> is the 

appropriate extension for the image format (.jpg, .tif, .png, etc)

Index Files:

 DAT files (separated by standard Concordance delimiters)

 First line must contain the column/field names

 Every row must have the same number of columns/fields (empty values are 

acceptable)

 Include relative pathing to each TXT File, Image File, or Native File. 

 Text must be encoded in UTF-8

 Values must be enclosed by Concordance standard delimiters 

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Specifications for the production of e-mail and attachments:

 The preferred method of receiving emails and their attachments is for 

them to be in consecutive order (parent email followed by corresponding

attachments).

 If emails and their attachments are produced as TIFF images with Text 

files, the Index File should contain the metadata fields listed in Paragraph

7, to the extent that they exist for a given document.

 If emails are being produced as native MSG files with attachments 

embedded, then provide extracted text in a single text file which contains 

the extracted text for both the parent e-mail and the attachment. Use a 

delimiter to set off the parent e-mail from the attachment. Pair the 

extracted combined text file with the MSG file.

 For emails, metadata is to include, but is not limited to: To, From, CC, 

BCC, Date Sent, Date Received, Subject, and any available information 

for the fields listed below in Paragraph 7.

Specifications for the production of native files, including, but not limited to, 

spreadsheet and audio or video files, e.g., Excel, MP3, AVI, etc.:

 Produce the native file, the corresponding extracted text, and the metadata.

 Metadata is to include, but is not limited to, Create Date, Last Edit Date,

Author, and any available information for the fields listed below in 

Paragraph 7.

 For Bates-numbered productions only, a slip sheet should be provided 

with the native file to enable linking to that file within a database. The 

name of the native file should match the Begin Bates number of the 

slipsheet. The slipsheet should also contain “Document Produced 

Natively” in the center of page, the Confidentiality branding, if any, in the 

bottom left corner of the page, and the Begin Bates number of the 

document in the bottom right corner of the pagealong with the original file 

name of that native file.

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The standard metadata fields that are to be produced include, but are not limited to, 

the following (where available):

 Begin Bates

 End Bates

 BegAttach (Begin Attachment Bates #)

 EndAttach (End Attachment Bates #)

 Author (Creator of document)

 LastAuthor

 To (Email To)

 From (Email From)

 BCC (Email BCC)

 CC (Email CC)

 Custodian

 All Custodians

 DateCRTD (Creation date; mm/dd/yyyy)

 DateLastMod (Date Last Modified; mm/dd/yyyy)

 DateRCVD (Date Received; mm/dd/yyyy)

 DateSent (mm/dd/yyyy)

 DocExt (Document Extension/File Type/Native Type/File Extension)

 FolderPath (Relative Path/File Path)

 E-mail Subject (Subject line of e-mail)

 Filename (Original file name)

 ParentID

 Title (Title provided by user within the document)

 MD5 Hash Value

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 Page Count

 Attachment Count

 Doc Type (Type of document, such as “Microsoft Excel Spreadsheet” or 

“Outlook E-mail,” etc.)

 Redacted (Y/N)

 Confidentiality (Y/N)

 Source (Name of Person or Entity who provided data)

Case 9:22-cv-81534-AHS Document 23-1 Entered on FLSD Docket 01/23/2023 Page 19 of 19