EXHIBIT C 

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IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION

OMAR HERNANDEZ and HANNAH

GOLDEN, individually and on behalf

of all others similarly situated,

Plaintiffs,

v.

ILLINOIS INSTITUTE OF

TECHNOLOGY,

Defendant.

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No.- 20-cv-3010

Judge Franklin U. Valderrama

Magistrate Judge Keri L. Holleb Hotaling

STIPULATED PROTOCOL ON THE DISCOVERY OF

ELECTRONICALLY STORED INFORMATION

This matter coming before the Court jointly by Plaintiffs, Omar Hernandez and Hannah 

Golden (“Plaintiffs”), and Defendant, Illinois Institute of Technology (“Defendant”) (hereinafter 

referred to individually as “Party” or collectively as “Parties”), having conferred pursuant to 

Fed.R.Civ.P. 26(f), and the Court having reviewed this matter hereby orders the following:

1) PURPOSE

This Stipulated Order will govern discovery of electronically stored information (“ESI”) 

in this case as a supplement to the Federal Rules of Civil Procedure, this Court’s Guidelines for 

the Discovery of Electronically Stored Information, and any other applicable orders and rules. 

2) GENERAL PRINCIPLES

The Parties are aware of the importance the Court places on cooperation and commit to 

cooperate in good faith throughout the matter consistent with this Court’s Guidelines for the 

Discovery of ESI.

Nothing in this Stipulated Order shall be interpreted to require disclosure of information 

protected by the attorney-client privilege, work product doctrine, or any other applicable privilege 

or immunity. Except as expressly provided herein, the Parties do not waive any objections as to 

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the production, discoverability, authenticity, admissibility, or confidentiality of any particular 

documents or ESI.

This Stipulated Order may be modified in the Court’s discretion or by agreement of the 

Parties for good cause shown. If the Parties cannot resolve their disagreements regarding these 

modifications, they may seek a resolution pursuant to the Federal Rules of Civil Procedure 

governing discovery disputes.

This Stipulated Order may only apply to the Parties.

3) DEFINITIONS

a. “Plaintiff” means and refers to the named plaintiffs in the above-captioned matter, 

as well as any later added plaintiffs, as well as their principals and agents.

b. “Defendant” means and refers to the named defendants in the above-captioned 

matter, as well as any later added defendants, as well as their directors, principals, 

employees, agents, and affiliated companies.

c. “Producing Party” means and refers to any Party(ies) that produces discovery or 

materials in this action. 

d. “Receiving Party” means and refers to any Party(ies) that receives discovery or 

materials in this action. 

e. “Document” is defined to be synonymous in meaning and equal in scope to the 

usage of this term in Rules 26 and 34 of the Federal Rules of Civil Procedure. The 

term “Document” shall include Hard-Copy Documents, Electronic Documents, and 

Electronically Stored Information (ESI) as defined herein.

f. “Electronic Document or Data” means Documents or Data existing in electronic 

form at the time of collection, including but not limited to: e-mail or other means 

of electronic communications, word processing files (e.g. Microsoft Word), 

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computer presentations (e.g. PowerPoint slides), spreadsheets (e.g. Excel), and 

image files (e.g. PDF).

g. “Hard-Copy Document” means Documents existing in paper form at the time of 

collection.

h. “Native Format” means and refers to the format of ESI in which it was generated 

and/or as used by the Producing Party in the usual course of its business and in its 

regularly conducted activities. For example, the native format of an Excel 

workbook is .xls or .xlsx.

i. “Near-Native Format” means and refers to the format of ESI that preserves the 

functionality, searchability, and integrity of a Native Format item when it is 

infeasible or unduly burdensome to produce the item in Native Format. For 

example, an MBOX is a suitable near-native format for production of Gmail, an 

Excel spreadsheet is a suitable near-native format for production of Google Sheets, 

and EML or MSG files may be suitable near-native formats for production of 

individual e-mail messages. Static images are not near-native formats for 

production of any form except Hard-Copy Documents.

j. “Metadata” means (i) information embedded in or associated with a native file that 

is not ordinarily viewable or printable from the application that generated, edited, 

or modified such native file which describes the characteristics, origins, usage, 

and/or validity of the electronic file; (ii) information generated automatically by the 

operation of a computer or other information technology system when a native file 

is created, modified, transmitted, deleted, or otherwise manipulated by a user of 

such system, (iii) information, such as Bates numbers, created during the course of 

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processing documents or ESI for production, and (iv) information collected during 

the course of collecting documents or ESI, such as file names, file paths, system 

dates, name of the media device on which it was stored, or the custodian or 

noncustodial data source from which it was collected.

k. “Optical Character Recognition” or “OCR” means the process of recognizing and 

creating a file containing visible text within an image.

4) PROPORTIONALITY

The Parties agree to use reasonable, good faith, and proportional efforts to identify, 

preserve, collect, process, analyze, review, and produce relevant Documents. This includes 

identifying and meeting and conferring on appropriate limits to discovery, including limits on 

custodians, identification of relevant subject matter, time periods for discovery, and other 

parameters to limit and guide discovery. It also includes the use of technology to achieve an 

efficient and effective discovery process.

5) PRESERVATION

The Parties have discussed their preservation obligations, as expressed in Fed. R. Civ. 

P. 37(e), and preservation needs, and agree that preservation of potentially relevant ESI will be 

reasonable and proportionate. To reduce the costs and burdens of preservation and to ensure proper 

ESI is preserved, the Parties agree that: 

a. Pursuant to section 5 below, the Parties have exchanged a list of the types of ESI 

they believe should be preserved and the custodians, or general job titles or 

descriptions of custodians, for whom they believe ESI should be preserved, e.g., 

“HR head,” “scientist,” and “marketing manager.” The Parties shall add or remove 

custodians as reasonably necessary;

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b. The Parties will agree on the number of custodians per party for whom ESI will be 

preserved;

c. These data sources are not reasonably accessible because of undue burden or cost 

pursuant to Fed. R. Civ. P. 26(b)(2)(B) and ESI from these sources will be 

preserved but not searched, reviewed, or produced: systems no longer in use that 

cannot be accessed.

d. Among the sources of data the Parties agree are not reasonably accessible, the 

Parties agree not to preserve the following: 

i. Automatically saved versions of documents whenever created;

ii. deleted, slack, fragmented, or unallocated data on hard drives;

iii. random access memory (RAM) or other ephemeral data;

iv. on-line access data such as temporary internet files, history, cache, or 

cookies;

v. data in metadata fields that are frequently updated automatically, such as 

last-opened dates;

vi. system or executable files (.exe, .dll, etc.);

vii. systems and materials retained primarily for backup or disaster recovery 

purposes;

viii. server, system or network logs; and

ix. other forms of Documents or ESI whose preservation requires extraordinary 

affirmative measures that are not utilized in the ordinary course of business.

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x. In addition to the agreements above, the Parties agree data from the 

following sources (a) could contain relevant information, but (b) under the 

proportionality factors, should not be preserved: N/A.

6) ESI DISCLOSURES

Prior to conducting searches for ESI in response to discovery requests, and in conjunction 

with negotiations on discovery requests, each Party shall disclose within a reasonable amount of 

time:

i. Custodians. The names, title, and roles of custodians most likely to have 

discoverable ESI in their possession, custody, or control. The custodians 

shall be identified by name, title, connection to the instant litigation, and the 

type of the information under the custodian’s control. 

ii. Non-custodial Data Sources. A list of non-custodial data sources (e.g., 

shared drives, servers, internal messaging applications), if any, likely to 

contain discoverable ESI. 

iii. Third-Party Data Sources. A list of third-party data sources, if any, likely to 

contain discoverable ESI (e.g., third-party email providers, mobile device 

providers, cloud storage, messaging providers) and, for each such source, 

the extent to which a party is (or is not) able to preserve information stored 

in the third-party data source.

iv. Custodial Data Sources. A list of sources of custodial documents and ESI 

including local hard drives, network home or personal file shares, 

removable storage, email, removable storage media, online storage such as 

Dropbox or Google Drive, phones, tables, and physical files.

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v. Inaccessible Data. A list of data sources, if any, likely to contain 

discoverable ESI (by type, date, custodian, electronic system or other 

criteria sufficient to specifically identify the data source) that a Party asserts 

is not reasonably accessible under Fed. R. Civ. P. 26(b)(2)(B).

vi. Documents and ESI from identified custodial and non-custodial data 

sources will be preserved pending identification of data to be produced in 

this litigation.

vii. The Parties have a continuing obligation to identify any other custodial and 

non-custodial data sources that may contain information relevant to this 

litigation and preserve them.

7) SEARCH METHODOLOGY

The Parties agree that in responding to an initial Fed. R. Civ. P. 34 request, or earlier if 

appropriate, they will meet and confer about methods to search ESI in order to identify ESI that is 

subject to production in discovery and filter out ESI that is not subject to discovery, such as 

whether to use search terms. No Party is required to run search terms and may instead use any 

other methodology that it proposes to use, including Technology Assisted Review (“TAR”), to 

locate ESI likely to contain responsive and discoverable information. 

The Parties shall meet and confer in good faith to reach agreement on appropriate search 

terms, file types, date restrictions, data sources, and custodians. The Parties shall continue to 

cooperate in revising the appropriateness of the search methodology, such as by the Producing 

Party providing hit count reports. The Producing Party may identify each search term or query 

returning overbroad results demonstrating the overbroad results and a counter proposal correcting 

the overbroad search or query.

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To the extent TAR methods are used, the Parties shall be prepared to discuss the 

reasonableness of such efforts. Documents and ESI that are captured by application of any agreedupon search methods or TAR technology does not mean that such Documents and ESI are 

necessarily responsive to any discovery request or are otherwise relevant to this litigation or any 

required disclosure, unless otherwise agreed upon by the Parties in writing. Whether or not a 

document is responsive shall be determined by the Producing Party after reviewing the Documents 

and ESI. The use of search terms, in particular, does not preclude the use of other reasonable 

techniques to further identify responsive or non-responsive Documents and ESI including, but not 

limited to, conceptual analytics and TAR. 

To the extent a response to discovery requires production of discoverable ESI contained in 

a structured database, the Parties shall meet and confer in an attempt to agree upon a set of queries 

to be made for discoverable information and generate a report in a reasonably usable and 

exportable electronic file for review by the Requesting Party. Upon review of the report, the 

Requesting Party may make reasonable requests for additional information to explain the database 

schema, codes, abbreviations, and different report formats or to request specific data from 

identified fields.

A Producing Party may always conduct a manual review for responsiveness and privilege, 

whether or not search terms or technology-aided review is also utilized. 

8) PRODUCTION FORMATS

Principles applicable to all productions of ESI and hard-copy documents.

a. The Parties agree to make rolling productions.

b. Documents will be produced to the Requesting Party with searchable text, in a 

format to be decided between the Parties. Acceptable formats include, but are not 

limited to, native files, multi-page TIFFs (with a companion OCR or extracted text 

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file), single-page TIFFs (only with load files for e-discovery software that includes 

metadata fields identifying natural document breaks and also includes companion 

OCR and/or extracted text files), and/or multi-page, searchable PDF.

c. Each document image file shall be named with a unique number (Bates Number). 

File names should not be more than twenty characters long or contain spaces.

d. Entire Document families shall be produced, unless the Producing Party has a legal 

basis to withhold part of the family based on applicable privileges or governing 

law. The Producing Party must redact, if possible, instead of withholding an entire 

document. Any documents withheld must be so indicated with a slipsheet 

placeholder or a full page redaction, enabling the remainder of the Document family 

to be produced and to preserve the familial relationship.

e. Document level extracted text or OCR for documents without extracted text will be 

provided by the Producing Party for every record, including for scanned hard copy 

documents as described above. Extracted text will not be provided for electronic 

documents that have been redacted because the extracted text would reveal the 

redacted information. Instead, these files will be re-OCRed to capture the visible 

text and those results will be provided in lieu of the original extracted text.

Metadata for redacted files may also be omitted, except for production-related 

fields (e.g., bates numbers and family relationship fields) that shall be provided in 

the load files.

f. The Parties are not obligated to populate manually any of the metadata fields set 

forth below if such fields cannot be reasonably extracted from a document. The 

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Parties reserve the right to request additional metadata fields should the Party show 

good cause for the necessity of such additional metadata. 

g. The Parties agree that this Stipulated Order governs only the format of electronic 

production of documents, and does not preclude a request for the production of 

documents by inspection of hard copy documents as they are kept in the usual 

course of business.

h. Confidentiality: The Parties will be entering into a confidentiality order in this 

matter, which will specify various confidentiality treatment levels for use in this 

case. The confidentiality treatment level for any item will be provided with the 

created data for that item, in the field entitled “Confidentiality Treatment.” For 

items with no confidentiality requirements, the field will be left blank. The 

Producing Party will brand any confidentiality endorsement in the lower left-hand 

corner on any PDFs or TIFF images representing the produced item. Those 

endorsements must be in a consistent font type and size and must not obscure any 

part of the underlying image or Bates number.

Principles applicable to ESI.

i. The Parties agree that, except as provided herein, ESI shall be produced in PDF or 

single-page Group IV TIFF, 300-dpi format and accompanied by an Opticon and 

IPRO load file (or other generally acceptable load file format) that contains 

document boundaries. Each PDF or TIFF file shall be given a unique file name that 

matches the Bates number label on first page of the PDF or of the corresponding 

TIFF file. The Bates number shall appear in the lower right-hand corner of images.

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j. Documents with hidden content, such as spreadsheets or presentations, shall be 

processed with all content unhidden and any notes displayed on the TIFF image. 

The Parties reserve all rights to meet and confer to request production of documents 

with hidden content in an alternate format. 

k. If a document is more than one page, the Parties shall make reasonable efforts, 

consistent with reasonable industry practices, to provide the logical unitization of 

the document, any attachments, and/or affixed notes as they exist in the original 

document.

l. The full text of each electronic document shall be extracted (“Extracted Text”) and 

produced in a text file. The Extracted Text shall be provided in searchable ASCII 

text format (or Unicode text format if the text is in a foreign language) and shall be 

named with a unique Bates Number (e.g., the unique Bates Number of the first page 

of the corresponding production version of the document followed by its file 

extension).

m. The Parties agree to produce documents using the Central Standard Time Zone.

n. The Parties may use analytics technology to identify email threads and need only 

produce the unique most inclusive copy and related family members and may 

exclude lesser inclusive copies. Upon reasonable request, the Producing Party will 

produce a less inclusive copy.

o. A Producing Party may de-duplicate electronic documents and is not obligated to 

extract or produce entirely duplicate ESI. Removal of duplicate documents shall 

only be done on exact duplicate documents based on MD5 hash values across 

custodians. However, family relationships will be maintained and only exact email 

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family groups will be de-duplicated. No email attachment will be de-duplicated 

against a loose file. Global de-duplication across the entire collection will be 

employed. This eliminates duplicates to retain only one copy of each document per 

case. For example, if an identical document resides with three custodians, only the 

first custodian’s copy will be included in the review set. The Custodian field will 

list the name of the custodian who was the source of the document. The Duplicate 

Custodian field will list the names of other custodians, separated by a semicolon, 

who also had the document and their copy deduped during processing. 

p. The Parties agree that the fields of metadata in Exhibit A shall be preserved, 

collected, and produced, only to the extent it is reasonably accessible and nonprivileged. This list of metadata is intended to be flexible and may be changed by 

agreement of the Parties, particularly in light of advances and changes in 

technology, vendor, and business practices.

q. Unless otherwise agreed to by the Parties, files that are not easily converted to 

image format, such as spreadsheet, database, and audio or video, will be produced 

in Native Format or Near-Native Format. If particular documents warrant a 

different format, the Parties will cooperate to arrange for the mutually acceptable 

production of such documents.

r. For documents produced in Native Format, the original native files should be 

produced in addition to a single-page TIFF placeholder for each document. The 

placeholder should be endorsed with “Native Format Document” or similar 

language, and endorsed with the Bates number assigned to that document. The 

produced native file should be named with the Bates number assigned to that 

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document. Any confidentiality or other designations stamped on the placeholder 

for such a document shall apply to the entire native file and its contents. For 

documents whose native format is MS Power Point, the original native files shall 

be produced with any comments and color preserved. The produced native file 

should be named with the beginning Bates numbers assigned to that document. The 

Parties will confer and agree upon the other types of files that are not easily 

converted to image format and will therefore be produced in Native Format. 

s. The relative path to the native file should be included in the delimited text file and 

the produced files should be organized in a “NATIVES” folder in the production 

media.

t. Native ESI, photographs, and video shall be produced in color if stored in color. 

Documents produced in color shall be produced as JPEG images, 300 dpi or higher 

and 24-bit color depth. All other documents should be produced in black and white, 

provided, however, that the color versions be preserved and produced upon the 

request of any Party. Except as already specified herein, the Parties agree to make 

a good faith effort to comply with reasonable and specific requests for the 

production of higher resolution or color images. Nothing in this order shall 

preclude a Producing Party from objecting to such requests as unreasonable in 

number, timing or scope, provided that a Producing Party shall not object if the 

document as originally produced is illegible or difficult to read. The Producing 

Party shall have the option of responding by producing a Native Format version of 

the document. If a dispute arises with regard to requests for higher resolution or 

color images, the Parties will meet and confer in good faith to try to resolve it. 

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Principles applicable to hard-copy documents.

u. The Parties agree that documents existing in hard copy form in Defendant’s 

possession should be produced in single-page Group IV, 300-dpi TIFF format and 

accompanied by an Opticon and IPRO load file (or other generally acceptable load 

file format). Each TIFF file will be given a unique file name that matches the Bates 

number label on the corresponding page. The accompanying load file shall contain, 

at a minimum, (a) ProdBeg, (b) ProdEnd, (c) BegAttach, (d) EndAttach, and 

(e) Custodian. The full extracted or OCR text should be included and produced at 

a document level and located in the same folder as their respective document image 

or OCR/TEXT folder.

v. The Parties agree that documents existing in hard copy form may be produced in 

searchable PDF if the parameters in paragraph (u) are unduly burdensome and not 

proportionate to the needs of the case. Each PDF file will be given a unique file 

name that matches the Bates number label on the first page of the document. 

w. The Parties will undertake best efforts to logically unitize documents correctly. In 

scanning hard-copy documents, 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). 

x. Text of hard-copy documents shall be extracted using industry-standard OCR 

technology. Text files shall not contain the redacted portions of the documents.

y. Responsive hard copy documents shall not be eliminated as duplicates of 

responsive ESI. 

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9) DOCUMENTS PROTECTED FROM DISCOVERY

The obligation to provide a log of privileged or work product materials presumptively shall 

not apply to: (a) Attorney work product created by Outside Counsel for the Parties regarding this 

litigation created after the filing of the first complaint; (b) Internal communications within Outside 

Counsel for the Parties regarding this litigation created after the filing of the first complaint; (c) 

Communications between Outside Counsel and the party they represent regarding this litigation 

after the filing of the first complaint. The Parties agree to confer regarding other categories of 

information that may be excluded from logging requirements.

The Parties agree that, except as provided herein regarding presumptively privileged 

documents and ESI, they will produce privilege logs and will exchange information regarding 

claims of privilege and/or work product protection within 30 days of a production. 

For documents and ESI that have been withheld or redacted as privileged, the withholding 

or redacting Party shall provide a privilege log of such documents and ESI, providing the following 

objective metadata to the extent it is reasonably available: date, author(s), custodian(s), 

recipient(s), file type, and subject (to the extent the subject does not reveal protected content). In 

addition, the withholding or redacting Party shall also provide for each document on their privilege 

log an identifier for the privilege being asserted (e.g., “ACP” for attorney client privilege, “WP” 

for work product, or other descriptions as necessary based on the specific privilege being claimed) 

and the document’s Bates numbers. 

The Parties reserve the right to request additional information regarding individual 

documents on the privilege log.

a. Limitations and Non-Waiver

Pursuant to Fed. R. Evid. 502(d), the production of a privileged or work-product-protected 

document, whether inadvertent or otherwise, is not a waiver of privilege or protection from 

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discovery in this case or in any other federal or state proceeding. This Order shall be interpreted 

to provide the maximum protection allowed by Federal Rule of Evidence 502(d). 

The Producing Party shall notify the Receiving Party that such material was unintentionally 

disclosed within ten (10) business days of learning of the inadvertent or unintentional disclosure 

of attorney-client or work product material. Thereafter, the Receiving Party shall return or destroy 

within five (5) business days the originals and all copies of the documents or things containing the 

allegedly privileged information. If the Receiving Party disagrees that the information is protected 

from disclosure by the attorney-client or work product privileges, or asserts there has been an 

intentional waiver of the privilege that encompasses the produced documents or things, the 

Receiving Party may keep any copies of such material and any original deposition exhibits while 

it moves the court, within fifteen (15) business days of the Producing Party’s written notice of 

inadvertent or unintentional disclosure (unless the Parties otherwise agree to a later period of time), 

for an order that such information be produced, in which case, the Party claiming the privilege 

shall have the burden of proving that such privilege exists. The motion to the court must be filed 

under seal and must not assert as a ground for compelling disclosure the fact or circumstances of 

the disclosure itself. The Receiving Party shall not use or rely upon any such documents or 

information until after the resolution of any such motion by the Court.

10) COSTS AND BURDEN

The Parties reserve the right to seek shifting or sharing of certain discovery costs, including 

vendor and attorney fees, in appropriate circumstances. 

11) PROTECTIVE ORDER

Nothing in this Stipulation shall be deemed to limit, modify, or override any provision of 

the any protective order entered in this action.

12) DISCOVERY DEFICIENCIES

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Prior to seeking court intervention, if a Requesting Party has good cause to believe that a 

Producing Party’s discovery efforts have been deficient, the Parties will meet and confer with the 

goal of identifying a means by which the Producing Party can provide assurances of the 

reasonableness of its discovery efforts, including, if necessary, identification of additional 

collection, review, and production criteria to cure the deficiency. If the Parties are unable to agree 

upon a means by which the Producing Party can provide assurances of the reasonableness of its 

discovery efforts, the Parties may seek appropriate court intervention. 

13) MODIFICATIONS

a. Any practice or procedure set forth herein may be varied by agreement of the 

Parties, and first will be confirmed in writing, where such variance is deemed 

appropriate to facilitate the timely and economical exchange of electronic data or 

other covered discovery materials.

b. Should any Party subsequently determine in good faith that it cannot proceed as 

required by this Order or that the Order requires modification, the Parties will meet 

and confer to resolve any dispute before seeking Court intervention.

IT IS SO ORDERED.

________________________________________

J.

PLAINTIFFS OMAR HERNANDEZ 

AND HANNAH GOLDEN

By: /s/ Daniel J. Kurowski

Daniel J. Kurowski

Whitney K. Siehl 

Hagens Berman Sobol 

Shapiro LLP

455 N. Cityfront Plaza Dr., Suite 2410

ILLINOIS INSTITUTE OF TECHNOLOGY

By: /s/ William T. “Toby” Eveland

One of its attorneys

William T. “Toby” Eveland 

(toby.eveland@saul.com)

Nancy DePodesta 

(nancy.depodesta@saul.com) 

James A. Morsch 

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Chicago, IL 60611

Telephone: (708) 628-4949

dank@hbsslaw.com

whitneys@hbsslaw.com

Steve W. Berman

Hagens Berman Sobol 

Shapiro LLP

1301 Second Avenue, Suite 2000

Seattle, WA 98101

TelephoneL (206) 623-7292

steve@hbsslaw.com

Eric M. Poulin (Pro Hac Vice)

Roy T. Willey, IV (Pro Hac Vice)

Paul J. Doolittle (Pro Hac Vice)

Blake G. Abbott (Pro Hac Vice)

POULIN | WILLEY | ANASTOPOULO, 

LLC

32 Ann Street

Charleston, SC 29403

(P): (803) 222-2222

(F): (843) 494-5536

eric@poulinwilley.com

roy@poulinwilley.com

Paul.doolittle@poulinwilley.com

Blake.abbott@poulinwilley.com

(jim.morsch@saul.com)

Elizabeth A. Thompson 

(elizabeth.thompson@saul.com)

Andrew E. Bollinger 

(andrew.bollinger@saul.com) 

Saul Ewing LLP

161 North Clark Street, Suite 4200, 

Chicago, Illinois 60601

(312) 876-7100

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FIELD NAME FIELD DESCRIPTION

PRODBEGDOC First Page document number

PRODENDDOC Last Page document number

PRODBEGATTACH First Page of Family group range number

PRODENDATTACH Last Page of Family group range number

CUSTODIAN The record owner of the file from whom the data was 

collected 

DUPLICATE CUSTODIAN The duplicate record owner(s) of the file from whom the 

data was collected and the record deduped during processing

HASH VALUE A unique, identifying number of a file calculated by a hash 

algorithm, e.g. MD5.

FROM Email Sender

TO Email Recipient(s)

CC Email Recipient(s) that were Copied

BCC Email Recipient(s) that were Blind Copied

SUBJECT Subject line of emails

THREADID Identification of email threads

PARENTID Identification of email parent relationships

FILENAME Name of file 

DATESENT Email sent date

TIMESENT Email sent time

DATERECEIVED Email received date

TIMERECEIVED Email received time

DATESAVED Save date

TIMESAVED Save time

FILEEXT File extension of document

AUTHOR Author of document

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FIELD NAME FIELD DESCRIPTION

TITLE Title from document metadata (if applicable)

DATECREATED Date document was created on non-emails

TIMECREATED Time document was created on non-emails

DATEMODIFIED Last date document was modified on non-emails

TIMEMODIFIED Last time document was modified on non-emails

FILESIZE Size of Native file

PGCOUNT Number of pages in document

OCRPATH Path to extracted text of native file or OCR

NATIVELINK Path to email or native file document (if applicable)

ORIGINALPATHFOLDER Path including filename

DOCTYPE Type of document (e.g., E-file, E-mail, or Attachment)

ATTACHMENTCOUNT Number of attachments

TIME ZONE Document time zone offset

CONFIDENTIALITY Confidentiality designation

REDACTIONS Identifies whether a document has redactions (Y or N)

Case: 1:20-cv-03010 Document #: 100-3 Filed: 02/07/24 Page 21 of 21 PageID #:1426