A0 888 (Rev. 02/ I4) Subpoena to Produce Documents, Information, or Objects or to Permit Inspection of Premises in a Civil Action

UNITED STATES DISTRICT COURT

 

 

for the
Northern District of Texas
Exxon Mobil Corporation 
Plainti?r 
v. Civil Action No. 
Maura Tracy Healey, Attorney General of 
Massachusetts. in her of?cial capacity, 
Defendant 

SUBPOENA TO PRODUCE DOCUMENTS, INFORMATION, OR OBJECTS
OR TO PERMIT INSPECTION OF PREMISES IN A CIVIL ACTION

To; 350.0rg, 20 Jay Street, Suite 732, Brooklyn, NY 11201

 

(Name of person to whom this subpoena is directed)

(I Production: YOU ARE COMMANDED to produce at the time, date, and place set forth below the following
documents, electronically stored information, or objects, and to permit inspection, copying, testing, or sampling of the
material:See Exhibit A attached hereto.

 

P121063 Paul, Weiss, Ri?<ind, Wharton Garrison LLP Date and Time:
1285 Avenue of the Americas .
New York, NY 10019-6064 1103/2016 5'00 pm

 

 

 

Inspection of Premises: YOU ARE COMMANDED to permit entry onto the designated premises, land, or
other pr0perty possessed or controlled by you at the time, date, and location set forth below, so that the requesting party
may inspect, measure, survey, photograph, test, or sample the property or any designated object or operation on it.

 

Place: Date and Time:

 

 

 

 

 

 

The following provisions of Fed. R. Civ. P. 45 are attached Rule 45(c), relating to the place of compliance;
Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and relating to your duty to
respond to this subpoena and the potential consequences of not doing so.

Date: ?l 70H,

CLERK OF COURT



Signature of Clerk or Deputy Clerk Attorney is signature

OR A


 

 

. .
The name, address, e-mail address, and telephone number of the attorney repre (name ofparty)
Exxon Mobil Corporation who issues or requests this subpoena, are:

Justin Anderson, Paul, Weiss, 2001 Street, NW, Washington, DC 20006, janderson@paulweiss.com, 202-223-7420

Notice to the person who issues or requests this subpoena
If this subpoena commands the production of documents, electronically stored information, or tangible things or the
inspection of premises before trial, a notice and a copy of the subpoena must be served on each party in this case before
it is served on the person to whom it is directed. Fed. R. Civ. P. 

 

A0 888 (Rev. 02/14) Subpoena to Produce Documents, Infomation, or Objects or to Permit Inspection of Premises in a Civil Action (Page 2)

 

Civil Action No. 

PROOF OF SERVICE
(This section should not be?led with the court unless required by Fed. R. Civ. P. 45.)

I received this subpoena for (name of individual and title, if any)

 

on (date)

I served the subpoena by delivering a copy to the named person as follows:

 

 

on (date) or

 

 

I returned the subpoena unexecuted because:

 

 

Unless the subpoena was issued on behalf of the United States, or one of its of?cers or agents, I have also
tendered to the witness the fees for one day?s attendance, and the mileage allowed by law, in the amount of



 

My fees are 3 for travel and for services, for a total of 0.00

I declare under penalty of perjury that this information is true.

Date:

 

Server ?5 signature

 

Printed name and title

 

Server '3 address

Additional information regarding attempted service, etc.:

 

 

A0 88B (Rev 02/14) Subpoena to Produce Documents, Information, or ObJects or to Pennit Inspection of Premises in a Action(Page 3)

Federal Rule of Civil Procedure 45 and (Effective 12/1/13)

Place of Compliance.

(1) For a Trial, Heating, or Deposition. A subpoena may command a
person to attend a trial, hearing, or deposrtion only as follows
(A) Within 100 miles of where the person resrdes, is employed, or
regularly transacts busmess in person, or
(B) Within the state where the person reSides, is employed, or regularly
transects busuiess in person, if the person
15 a party or a party?s of?cer, or
(ii) is commanded to attend a trial and would not mcur substantial
expense

(2) For Other Discovery. A subpoena may command
(A) production of documents, electromcally stored information, or
tangible things at a place Within 100 miles of where the person reSides, is
employed, or regularly transacts busmess in person, and
(B) inspection of prenuses at the premises to be inspected

Protecting a Person Subject to a Subpoena; Enforcement.

(1) Avoiding Undue Burden or Expense; Sanctions. A party or attorney
for issuing and servmg a subpoena must take reasonable steps
to avord imposmg undue burden or expense on a person subject to the
subpoena The court for the district where compliance is required must
enforce this duty and impose an appropriate sanction?which may include
lost earnings and reasonable attorney?s fees?on a party or attorney who
fails to comply

(2) Command to Produce Materials or Permit Inspection.

(A) Appearance Not Required A person commanded to produce
documents, electronically stored information, or tangible things, or to
permit the mspection of prenuses, need not appear in person at the place of
production or inspection unless also commanded to appear for a deposrtion,
hearing, or trial

(B) Objections A person commanded to produce documents or tangible
things or to perrmt Inspection may serve on the party or attorney desrgnated
in the subpoena a written objection to inspecting, copying, testing, or
sampling any or all of the materials or to uispecting the prenuses?or to
producmg electronically stored information in the form or forms requested
The objection must be served before the earlier of the time speci?ed for
compliance or 14 days after the subpoena is served If an objection 18 made,
the following rules apply

At any time, on notice to the commanded person, the servmg party
may move the court for the district where compliance is required for an
order compelling production or inspection

(ii) These acts may be reqmred only as directed in the order, and the
order must protect a person who is neither a party nor a party?s o?cer ??om
Signi?cant expense resulting from compliance

(3) Quashing or Modifying a Subpoena.
(A) Mien Required On timely motion, the court for the district where
compliance is required must quash or modify a subpoena that
fails to allow a reasonable time to comply,
(ii) requires a person to comply beyond the geographical [units
speci?ed in Rule 45(c),
(iil) requrres disclosure or other protected matter, if no
exception or waiver applies, or
(iv) subjects a person to undue burden
(B) When Permitted To protect a person subject to or a?ected by a
subpoena, the court for the district where compliance 15 required may, on
motion, quash or modify the subpoena if it requires
diSclosmg a trade secret or other con?dential research,
development, or commercial information, or

(ii) disclosmg an unretamed expert?s opinion or information that does
not describe speci?c occturences in dispute and results ?'om the expert?s
study that was not requested by a party

(C) Speci?ting Conditions as an Alternative In the Circumstances
described in Rule the court may, instead of quashing or
modifymg a subpoena, order appearance or production under specr?ed
conditions if the party

shows a substantial need for the testimony or material that cannot be
otherwrse met Without undue hardship, and

(ii) ensures that the subpoenaed person Will be reasonably compensated

Duties in Responding to a Subpoena.

(1) Producing Documents or Electronically Stored Information. These
procedures apply to producing documents or electronically stored
information

(A) Documents A person responding to a subpoena to produce documents
must produce them as they are kept in the ordinary course of or
must organize and label them to correspond to the categories in the demand

(B) arm for Producmg Electronically Stored Information Not Specified
If a subpoena does not specify a form for producing electronically stored
information, the person responding must produce it in a form or forms in
which it is ordinarily maintained or in a reasonably usable form or forms

(C) Electronically Stored Produced in Only One arm The
person responding need not produce the same electromcally stored
mfomiation in more than one form

(D) Electronically Stored Information The person
responding need not provrde discovery of electronically stored information
from sources that the person identi?es as not reasonably because
of undue burden or cost On motion to compel discovery or for a protective
order, the person responding must show that the information is not
reasonably acce53ible because of undue burden or cost If that showmg is
made, the court may nonetheless order discovery from such sources if the
requesting party shows good cause, consrdering the [mutations of Rule
The court may specrfy conditions for the discovery

(2) Claiming Privilege or Protection.

(A) Information Withheld A person Withholding subpoenaed information
under a claim that it is privrleged or subject to protection as trial-preparation
material must

expressly make the claim, and

(ii) describe the nature of the Withheld documents, communications, or
tangible things in a manner that, Without revealing information itself
or protected, enable the parties to assess the claim

(B) Information Produced If information produced in response to a
subpoena 15 subject to a claim of or of protection as
trial-preparation material, the person making the claim may notify any party
that received the information of the claim and the bass for it After being
noti?ed, a party must return, sequester, or destroy the speci?ed
information and any copies it has, must not use or disclose the information
until the claim is resolved, must take reasonable steps to retrieve the
information if the party disclosed it before being noti?ed, and may 
present the information under seal to the court for the district where
compliance 18 required for a determination of the claim The person who
produced the information must preserve the information until the claim is
resolved

Contempt.

The court for the district where compliance is required?and also, after a
motion is transferred, the issumg court?may hold in contempt a person
who, havmg been served, fails Without adequate excuse to obey the
subpoena or an order related to it

 

For access to subpoena materials, see Fed Civ 45(a) Commutee Note (2013)

 

 

 

EXHIBIT A

 

EXHIBIT A

This subpoena calls for the recipient to produce the documents described
under the heading ?Requests? below in accordance with the accompanying ?De?nitions?
and ?Instructions.?

DEFINITIONS

1. ?And? and ?or? shall be construed either disjunctiver or
conjunctiver as to bring within the scope of the request all information or documents
that might otherwise be construed to be outside of its scope.

2. ?All? shall be construed to include ?any? and ?each,? ?any? shall
be construed to include ?all? and ?each,? and ?each? shall be construed to include ?all?
and ?any,? in each case as is necessary to bring within the scope of these requests
documents that might otherwise be construed as outside their scope.

3. The terms ?all? and ?each? shall be construed as all and each.

4. ?Any? is used in its inclusive sense. For example, if a Request
calls for ?any communication that You had with the defendant,? You should produce
each and every communication with the defendant.

5. ?Communication? means any conversation, discussion, letter,
electronic mail (?email?), memorandum, meeting, note, or other transmittal of
information or message, whether transmitted in writing, orally, electronically or by any
other means, and shall include any document that abstracts, digests, transcribes, records,
or re?ects any of the foregoing. Except where otherwise stated, a request for

?Communications? means a request for all communications.

 

6. ?Concerning? means referring or relating to and includes without
limitation analyzing, commenting on, comprising, connected with, constituting,
containing, contradicting, describing, embodying, establishing, evidencing,
memorializing, mentioning, pertaining to, recording, regarding, re?ecting, responding to,
setting forth, showing, or supporting, directly or indirectly.

7. ?Custodian? means any person or entity that, as of the date of this
Request for Production, maintained, possessed, or otherwise kept or controlled such
document.

8. ?Date? shall mean the exact date, month and year, if ascertainable
or, if not, the best approximation of the date (based upon relationship with other events).

9. ?Document? is used herein in the broadest sense of the term and
means all records and other tangible media of expression of whatever nature however and
wherever created, produced, or stored (manually, mechanically, electronically, or
otherwise), including Without limitation all versions whether draft or ?nal, all annotated
or nonconforming or other copies, email, instant messages, text messages, personal
digital assistant or other wireless device messages, voicemail, calendars, date books,
appointment books, diaries, books, papers, ?les, notes, con?rmations, accounts
statements, correspondence, memoranda, reports, records, journals, registers, analyses,
plans, manuals, policies, telegrams, faxes, telexes, wires, telephone logs, telephone
messages, message slips, minutes, notes, or records or transcriptions of conversations or
communications or meetings, tape recordings, videotapes, disks, and other electronic
media, micro?lm, micro?che, storage devices, press releases, contracts, agreements,

notices, and summaries. Any non-identical version of a document constitutes a separate

 

document within this de?nition, including without limitation drafts or copies bearing any
notation, edit, comment, marginalia, underscoring, highlighting, marking, or any other
alteration of any kind resulting in any difference between two or more otherwise identical
documents. In the case of documents bearing any notation or other marking made by
highlighting ink, the term document means the original version bearing the highlighting
ink, which original must be produced as opposed to any copy thereof. Except where
otherwise stated, a request for ?documents? means a request for all such documents.

10. ?Entity? means without limitation any corporation, company,
limited liability company or corporation, partnership, limited partnership, association, or
other ?rm or similar body, or any unit, division, agency, department, or similar
subdivision thereof.

11. ?Identify? means: when referring to a person or persons, to
state the name and present address or, if unknown, the last known address, telephone
number, e-mail address, title and employer of such person or persons; when referring
to a ?rm, partnership, corporation, association or other entity, to state the full name,
address and telephone number or, if unknown, the last known address and telephone
number; when referring to documents, to state, to the extent known, the type of
document; (ii) general subject matter; date of the document; and (iv) author(s),
addressee(s) and recipient(s); when referring to communications, to state, to the extent
known, the date of the communication; (ii) identity of the parties to the
communication; means of transmission of the communication; and (iv) identity of all

documents memorializing all or part of the communication. To the extent any responsive

 

communication is memorialized in a document, please produce a copy of the document
for inspection and copying.

12. ?Including? means ?including without limitation.?

13. ?Information? shall be construed expansiver and shall include,
but not be limited to, facts, data, opinions, documents, communications, images,
impressions, concepts and formulae.

14. ?Person? includes any natural person, ?rm, partnership, joint
venture, corporation, sole proprietorship, trust, union, association, federation, labor
organizations, legal representatives, trustees, trustees in bankruptcy, receivers, business
entities, any other form of business, governmental, public, charitable entity, or group of
natural persons or such entities.

15. ?Refer? means embody, refer or relate, in any manner, to the
subject of the document request.

16. ?Civil Investigative Demand? or means the civil
investigative demand issued by the of?ce of Defendant Attorney General Maura Healey
to ExxonMobil on or about April 19, 2016.

17. ?Common Interest Agreement? means the Climate Change
Coalition Common Interest Agreement signed by individuals from the of?ces of the
attorneys general for California, Connecticut, Illinois, Maine, Maryland, Massachusetts,
Minnesota, New Hampshire, New Mexico, New York, Oregon, Rhode Island, Virginia,
US. Virgin Islands, Vermont, Washington, and Washington, DC, in April and May of

2016.

 

18. ?Green 20? means the attorneys general for the States,
Commonwealths, or Territories of California, Connecticut, Delaware, Hawaii, Illinois,
Iowa, Maine, Maryland, Massachusetts, Minnesota, New Hampshire, New Mexico, New
York, Oregon, Rhode Island, the US. Virgin Islands, Vermont, Virginia, Washington,
and Washington, the Of?ces of these attorneys general; their directors, of?cers,
employees, agents, representatives or other persons acting, or purporting to act, on their
behalf, including, but not limited to, Assistant Attorneys General.

19. ?Green 20 Press Conference? or United for Clean Power
Press Conference? means the Press Conference attended by Defendant Attorney General
Maura Healey and other members of the Green 20 on March 29, 2016.

20. ?Investigation? means an actual or contemplated issuance of a
subpoena, Civil Investigative Demand, or any other investigative process concerning
purported violations of law related to climate change.

21. ?You,? ?Yours,? and/or ?Yourself? mean 350.0rg, as well as its
directors, of?cers, employees, agents, representatives or other persons acting, or

purporting to act, on its behalf.

INSTRUCTIONS
22. Any ambiguity as to any Request shall be construed so as to
require the production of the greater number of documents.
23. These Requests are continuing in nature under Federal Rule of
Civil Procedure 26(e). Any document created or identi?ed after service of any response

to these Requests that would have been produced in response had the document then

 

existed or been identi?ed shall be produced whenever You ?nd, locate, acquire,
create, or become aware of such documents, up until the resolution of this lawsuit.

24. Each Request shall be responded to fully, unless it is in good faith
objected to, in which event the reasons for the objection shall be stated with speci?city.
If an objection pertains only to a portion of a Request, or to a word, phrase, or clause
contained in a Request, You shall state Your objection to that portion only and respond to
the remainder of the request.

25. Documents that are produced should be identi?ed according to
which request they are responsive to, or in the order in which they are kept in the
ordinary course of business. All documents that are physically attached to each other
when located for production shall be left so attached. Documents that are segregated or
separated from other Documents, whether by inclusion of binders, ?les, sub?les, or by
use of dividers, tabs, clips, or any other method, shall be left so segregated or separated.

26. Where any copy of any document, the production of which is
requested, is not identical to any other copy thereof, by reason of any alterations,
marginal notes, comments, metadata, omissions, or material contained therein or attached
thereto, or otherwise, all such non-identical copies shall be produced separately.

27. If any document responsive to these Requests has been destroyed,
discarded, or lost, or is otherwise not capable of being produced, identify each such
document and set forth the following information: the date of the document; a
description of the subject matter of the document; (0) the name and address of each
person who prepared, received, viewed, or had possession, custody, or control of the

document; the date when the document was destroyed, discarded, or lost; the

 

identity of the person who directed that the document be destroyed, who directed that the
document be discarded, or who lost the document; and a statement of the reasons for
and circumstances under which the document was destroyed, discarded, or lost.

28. If You withhold or redact any Document responsive to this
Subpoena on ground of privilege or other legal doctrine, you shall contemporaneously
submit with the Documents produced a statement in writing, stating: the document
control number(s) of the Document withheld or redacted; the type of Document; (0)
the date of the Document; the author(s) and recipient(s) of the Document; the
general subject matter of the Document; and the legal ground for withholding or
redacting the Document. If the legal ground for withholding or redacting the Document is
attomey-client privilege, you shall indicate the name of the attomey(s) whose legal
advice is sought or provided in the Document.

29. You shall further certify that the document production is complete
and correct in accordance with speci?cations of the attached Certi?cation that Response
is Complete and Correct form provided as Exhibit B.

30. Pursuant to Fed. R. Civ. P. Plaintiff requests that all
electronically stored information be produced in accordance with the ?Requested
Production Format? provided as Exhibit C.

31. Each request shall be deemed to include a request for all
transmittal sheets, cover letters, exhibits, enclosures, and attachments to a document in
addition to the Document itself, without abbreviation or expurgation.

32. If no documents or things exist that are responsive to a particular

paragraph of these requests, so state in writing.

 

33. Unless otherwise stated in a speci?c request, these requests seek
responsive information and documents authored, generated, disseminated, drafted,
produced, reproduced, or otherwise created or distributed, concerning the period of
January 1, 2012, through the date of production.

34. These requests call for the production of responsive documents
within Your possession, custody, or control (including those on email servers not
associated with 350.0rg), regardless of whether those documents were generated and/or
are maintained by 350.0rg.

35. The foregoing De?nitions and Instructions also apply to the
De?nitions and Instructions themselves.

DOCUMENTS AND THINGS TO BE
PRODUCED BY 350.0RG

1. Any and all documents suf?cient to show and identi? any
communications between 350.0rg, 350.0rg?s agents, representatives, or employees and
any Attorney General or their directors, of?cers, employees, agents, representatives or
other persons acting, or purporting to act, on their behalf, including, but not limited to,
Assistant Attorneys General, concerning the decision of an Attorney General regarding
whether to investigate ExxonMobil. This request includes any communications in which
350.0rg advocated that an Attorney General initiate an investigation of ExxonMobil,
participate in the Green 20 Press Conference, announce approval for or alignment with
the investigation of ExxonMobil by any Attorney General, and/or collaborate, cooperate,
or work in concert with Attorneys General who were or are investigating ExxonMobil.

2. Any and all documents, recordings, or other materials concerning

any meetings regarding any investigation of ExxonMobil related to climate change that

 

350.org or 350.0rg?s agent, employee, or representative attended, which was also
attended by any Attorney General, or his/her directors, of?cers, employees, agents,
representatives or other persons acting, or purporting to act, on his/her behalf, including,
but not limited to, Assistant Attorneys General. This request includes, without limitation,
Video recordings, audio recordings, photographs, attendance logs, notes, and meeting
minutes.

3. For the time period January 1, 2015 through the date of production,
any and all documents suf?cient to show and identify any fees or expenses paid to former
Vice President Al Gore in connection with his participation in or attendance at the Green
20 Press Conference.

4. Any and all documents and communications concerning the
Common Interest Agreement entered into by members of the Green 20.

5. Any and all documents, recordings, or materials of any kind
discussed or presented during any meeting concerning the conference entitled
?Establishing Accountability for Climate Change Damages: Lessons from Tobacco
Control? held in La olla, California from on or about June 14, 2012 to on or about June
15, 2012.

6. Any and all documents concerning the actual or anticipated
participation of ExxonMobil or other fossil fuel companies or trade associations in the
international Paris Climate Change Conference of December 2015.

7. Any and all documents concerning any shareholder resolution
relating to climate change made at ExxonMobil?s annual shareholder meeting in either

2015 or 2016.

 

8. Any and all documents and communications concerning
fundraising for candidates for political of?ce, including fundraising for any member of
the Green 20, and also concerning ExxonMobil.

9. Any and all documents, recordings, or materials of any kind that
were discussed or presented during any meeting concerning the mock trial referred to as
?Exxon vs. The People? held in or around Montreuil, France on or about December 5,
2015.

10. Any and all communications between 350.0rg, 350.0rg?s agents,
representatives, or employees and any member of the Green 20 concerning the mock trial
referred to as ?Exxon vs. The People? held in or around Montreuil, France on or about
December 5, 2015.

11. Documents and records suf?cient to identify 350.0rg?s document
retention policy.

12. Documents and records suf?cient to identify any and all
documents or communications within the scope of these requests that were disposed of or

destroyed since April 13, 2016.

10

 

EXHIBIT 

 

CERTIFICATION THAT RESPONSE IS CORRECT AND COMPLETE

I, certify as follows:

 

 

l. I am employed by in the position of

 

2. The enclosed production of documents and responses were prepared and assembled
under my personal supervision;

3. I made or caused to be made a diligent, complete and comprehensive search for all
Documents and information requested by the Subpoena, in full accordance with the
instructions and de?nitions set forth in the Subpoena;

4. The enclosed production of Documents and information requested by the Subpoena are
complete and correct to the best of my knowledge and belief;

5. No Documents or information responsive to the Subpoena have been withheld from
this production and response, other than responsive Documents or information withheld
on the basis of a legal privilege or doctrine;

6. All responsive Documents or information withheld on the basis of a legal privilege or
doctrine have been identi?ed on a privilege log composed and produced in accordance
with the instructions in the Subpoena;

7. The Documents contained in these productions and responses to the Subpoena are
authentic, genuine and what they purport to be;

8. Attached is a true and accurate record of all persons who prepared and assembled any
productions and responses to the Subpoena, all persons under whose personal supervision
the preparation and assembly of productions and responses to the Subpoena occurred, and
all persons able competently to testify: that such productions and responses are
complete and correct to the best of such person's knowledge and belief; and that any
Documents produced are authentic, genuine and what they purport to be; and

9. Attached is a true and accurate statement of those requests under the Subpoena as to
which no responsive Documents were located in the course of the aforementioned search.

Signature: Date:

 

Printed Name:

 

Address, e-mail and telephone number:

 

 

 

 

EXHIBIT 

 

II.



Overview

REQUESTED PRODUCTION FORMAT

A. All documents should be produced as Bates-stamped tagged image ?le format
images along with an image load/cross reference ?le, a data load ?le
with ?elded metadata, and document-level extracted text for electronically stored
information or optical character recognition text for scanned hard copy
documents. Details regarding requirements, including ?les to be delivered in
native format, are below.

TIFF Image Requirements

A. All documents should be produced as TIFF images in 300x300 dpi Group IV
single-page monochrome format.

B. All such images should be sequentially Bates-stamped.

C. Images should include the following content where present:
I. For word processing ?les Microsoft Word) Comments and ?track
changes? (and similar in-line editing).
2. For spreadsheet ?les Microsoft Excel) Hidden columns, rows, and
sheets; comments; and ?track changes? (and similar in-line editing).
3. For presentation ?les g, Microsoft PowerPoint) Speaker notes and

comments.

Native Format Requirements

A. Spreadsheet ?les

1.

2.

Spreadsheet ?les Microsoft Excel) should be provided in native
format.

In lieu of a TIFF image version of each spreadsheet ?le, a Bates?stamped
single-page TIFF placeholder ?le should be produced along with the
native format version of each ?le.

When redaction is necessary, a redacted TIFF version may be produced;
Paul Weiss reserves the right to request access to the native format
versions of such ?les.

B. Multimedia ?les

1.

2.

Multimedia ?les Audio or video ?les) should be provided in native
format.

In lieu of a TIFF image version of each multimedia ?le, a Bates-stamped
single-page TIFF placeholder ?le should be produced along with the
native format version of each ?le.

 

C.

Other ?les

1. In limited circumstances, it may be necessary to obtain or view the native
format versions of ?les, including color documents/images and dynamic
?les such as databases. Paul, Weiss reserves the right to request access to
the native format versions of such ?les.

IV. Image Load/Cross Reference File Requirements

A.

B.

A single-page image load/cross reference ?le should be provided with each
production.

The ?le may be in either IPRO (.lfp) or Opticon (.opt) format as in the samples
below (note that volume label information in the sample IPRO
?le and in the sample Opticon ?le is optional):

Sample .ljfp?le



1M,Msc00000017,,0,@Msc001; 

Sample Opticon .opt?le






V. Data Load File and Extracted Requirements

A.

B.

A data load ?le should be provided with each production.

The ?le should be a Concordance-loadable data ?le, also known as a ?le,
and should contain Bates-stamp and metadata information as detailed below.

Extracted text and/or OCR text should not be embedded in the DAT ?le but
should rather be provided as separate, document-level text ?les. Document-level
text ?le names should contain the beginning Bates number information of the
document. If a document is provided in native format with a placeholder tiff, 
spreadsheet ?les) the text ?le should contain the extracted text of the native ?le.
OCR text should be included for redacted documents.

The requested delimiters and quali?ers to be used in the DAT ?le are:

Record delimiter: Windows newline/Hard return (ASCII 10 followed by ASCII
13)

Field delimiter: (ASCII 20)

Multi-value delimiter: Semicolon (ASCII 59)

Text qualifier: Small thorn (ASCII 254)

2

 

E.

The DAT ?le should have a header line with ?eld names and include the

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

following ?elds:
Field Comments

BegBates Beginning Bates number

EndBates Ending Bates number

BegRange Bates number of ?rst page of family range, e. g, ?rst page of
an email.

EndRange Bates number of last page of family range, e. last page of
last attachment to an email.

PageCount Number of pages in document.

ileExtension Loose ?les, attachments and email.

FileSize Loose ?les, attachments and email (in bytes).

Title Loose ?les and attachments only.

Custodian Include ?eld only if production is de-duped by custodian.
Loose ?les, attachments, and email. Custodian full name
formatted: LASTNAME, FIRSTNAME.

AllCustodian Include ?eld only if production is de-duped globally. Loose
?les, attachments, and emails. Full name of all custodians
for whom the document is being produced formatted:
LASTNAME, LASTNAME, FIRSTNAME

Author Loose ?les and attachments only.

From Email only.

To Email only.

CC Email only.

BCC Email ow.

Subject Email o?y.

DateCreated Loose ?les and attachments only. 

DateModi?ed Loose ?les and attachments only. 

DateSent Email only. 

TimeSent Email only. 

DateReceived Email only. 

TimeReceived Email ow. 

FilePath Loose ?les. Original path to the ?le as maintained in the
ordinary course of business.

FileName Loose ?les and attachments. Name of ?le as maintained in
the ordir?y course of business.

FolderPath Email only. Path within the mail container ?le g. PST
?le) to the message at collection time.

HiddenContent For loose ?les and attachments only. List type of hidden
content found in document (for content described in section
II.C above)

TextPath The path to the extracted text or OCR for the document,

 

including the ?le name.