A0 88B (Rev. 02/14) 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?' v. Civil Action No. Maura Tracy Healey, Attomey 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: Carroll Muffett, 1350 Connecticut Avenue, Suite #1100, Washington DC. 20036 (Name of person to whom this subpoena is directed) 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. Place: Paul, Weiss, Rifkind, Wharton 8. Garrison LLP Date and Time: 2001 Street, NW . Washington, DC. 20006 1103,2016 5-00 Pm Cl Inspection of Premises: YOU ARE COMMANDED to permit entry onto the designated premises, land, or other property 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(0), 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: a? 70119 CLERKOFCOURT Signature of Clerk or Deputy Clerk Attorney ?3 signature The name, address, e-mail address, and telephone number of the attorney esenting (name ofparo?) 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 cepy 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 883 (Rev. 02/14) Subpoena to Produce Documents, Information, 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.) 1 received this subpoena for (me ofindividuai and title, ifany) on (date) El 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 officers 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 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 ?5 address Additional information regarding attempted service, etc.: A0 883 (Rev 02/14) Subpoena to Produce Documents, lnfonnatton, or Objects or to Permit Inspection of Premises tn a Action(Page 3) Federal Rule of Civil Procedure 45 and (Effective 12/1/13) Place of Compliance. (1) For a Trial, Hearing, or Deposition. A subpoena may command a person to attend a trial. hearuig, or deposrtton only as follows (A) 100 mtles of where the person resrdes, ts employed, or regularly transacts busmess in person, or (B) the state where the person resides, ts employed, or regularly transects busmess in person, if the person ts a party or a party?s officer, or (it) IS commanded to attend a trial and would not incur substantial expense (2) For Other Discovery. A subpoena may command (A) production of documents, electronically stored information, or tangible at a place 100 miles of where the person reSides, ts employed, or regularly transacts busmess tn person, and (B) inspection of premises at the premtses to be inspected Protecting a Person Subject to a Subpoena; Enforcement. (1) Avoiding Undue Burden or Expense; Sanctions. A party or attorney responsible for issumg and servmg a subpoena must take reasonable steps to award 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 approprtate sanction?which may include lost earnings and reasonable attomey?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 mfonnatton, or tangible things, or to pennit the of premises, need not appear tn person at the place of production or inspection unless also commanded to appear for a deposnton, hearmg, or trial (B) Objecllons A person commanded to produce documents or tangible or to permit inspection may serve on the party or attorney demgnated in the subpoena a written objection to inspecting, copying, testing, or sampling any or all of the matenals or to mspecting the premises?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 a?er the subpoena is served If an objection ts made, the following rules apply At any time, on notice to the commanded person, the sewing party may move the court for the district where compliance is required for an order compelling production or inspection (it) These acts may be reqiured only as directed tn die order, and the order must protect a person who is neither a party nor a party?s of?cer ?om Signi?cant expense resulting from compliance (3) Quoshing or Modifying a Subpoena. (A) When Required On timely motion, the court for the district where compliance is requtred must quash or modify a subpoena that fails to allow a reasonable time to comply, (ii) rcqu tres a person to comply beyond the geographical [units speci?ed in Rule 45(0), reqmres disclosure of or other protected matter, if no exception or waiver applies, or (iv) a person to undue burden (B) When Permitted To protect a person subject to or affected by a subpoena, the court for the where compliance is required may, on motion, quash or modify the subpoena if it requires (0 a trade secret or other con?dential research. development, or commercml mformatton, or (ii) disclosmg an unretamed expert?s Opinion or information that does not describe speci?c occurrences tn dispute and results [tom the expert?s study that was not requested by a party (C) as an Alternative In the circumstances described at Rule the court may, instead of quashmg or modttying a subpoena, order appearance or production under speci?ed conditions if the servmg shows a substantial need for the testimony or material that cannot be otherwise met Without undue hardship, and (ll) ensures that the subpoenaed person Will be reasonably compensated Duties in Responding to a Subpoena. Producing Documents or Electronically Stored Information. These procedures apply to productng 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 busmess or must organize and label them to correspond to the categories the demand (B) arm for Producing Electronically Stored Infannanon Not Speci?ed [fa subpoena does not specify a form for producing electronically stored mformatton, the person responding must produce it in a form or forms tn which it is ordmarily maintained or tn a reasonably usable form or forms (C) Electronically Stored Produced in Only One Form The person responding need not produce the same electromcally stored information in more than one form (D) Inaccessible Elecronzcalbr Stored Information The person responding need not provtde discovery of electronically stored mformatton ?'Om sources that the person identi?es as not reasonably accessthe because of undue burden or cost On motion to compel discovery or for a protecttve order, the person responding must show that the information is not reasonably because of undue burden or cost If that showmg is made, the court may nonetheless order discovery ?'om such sources if the requesting party shows good cause, conStdertng the lnmtations of Rule The court may specify conditions for the discovery (2) Claiming Privilege or Protection. (A) A person Withholding subpoenaed information under a claim that it ts pnwleged or subject to protection as coal-preparation material must (I) expressly make the claim, and (ii) describe the nature of the Withheld documents, communications, or tangible things in a manner that, Without revealtng information itself prmleged or protected, W111 enable the parties to assess the claim (B) In?imanon Produced If information produced in response to a subpoena ts subject to a claim of priVIlege 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 mformation until the claim is resolved, must take reasonable steps to remeve the information if the party disclosed it before being noti?ed, and may present the information under seal to the court for the where compliance is required for a determmatton 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 motton ts transferred, the issuing 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 45(a)Comm1ttee 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 disjunctively or conj unctively 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 ?eac 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. 1 1. ?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; (0) 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 expansively 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 Carroll Muffett, as well as Your employees, agents, representatives or other persons acting, or purporting to act, on Your 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; 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 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; 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 attorney(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 personal email servers), regardless of whether You generated and/or maintain those documents. 35. The foregoing De?nitions and Instructions also apply to the De?nitions and Instructions themselves. DOCUMENTS AND THINGS TO BE PRODUCED BY CARROLL MUFFETT 1. Any and all documents suf?cient to show and identify any communications between You, Your 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 You 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 You or Your 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 period January 1, 2015 through the date or 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 Jolla, 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 discussed or presented during any meeting concerning the ?Exxon: Revelations Opportunities? event held on or about January 8, 2016 at 475 Riverside Drive, New York, New York. 10. Any and all documents suf?cient to show and identify any communications between You, Your agents, representatives, or employees, and any member of the Green 20 concerning the ?Exxon: Revelations Opportunities? meeting held on or about January 8, 2016 at 475 Riverside Drive, New York, New York. 11. Any and all communications between You, Your 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. 12. Documents and records suf?cient to identify Your document retention policy. 13. 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: 1. 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: 1. 2. 3. For word processing ?les Microsoft Word) Comments and ?track changes? (and similar in-line editing). For spreadsheet ?les Microsoft Excel) - Hidden columns, rows, and sheets; comments; and ?track changes? (and similar in-line editing). For presentation ?les Microsoft PowerPoint) Speaker notes and cements. Native Format Requirements A. Spreadsheet ?les 1. 2. Spreadsheet ?les g, 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. Image Load/Cross Reference File Requirements A. A single-page image load/ cross reference ?le should be provided with each productioneither 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 IPRO .ljjv?le Sample Opticon .opt ?le Data Load File and Extracted Requirements A. A data load ?le should be provided with each production. B. 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. C. 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. D. 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, ?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. FileExtension 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 om. Subject Email om. DateCreated Loose ?les and attachments only. DateModi?ed Loose ?les and attachments only. DateSent Email only. TimeSent Email ogy. DateReceived Email only. TimeReceived Email only. FilePath Loose ?les. Original 'path to the ?le as maintained in the ordinary course of business. FileNarne Loose ?les and attachments. Name of ?le as maintained in the ordinary 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. Field Comments NativePath The path to the native?format ?le for the document, including the ?le name (if a native-format ?le is provided). F. Two sample DAT ?les in the appr0priate format when production is globally de- duped are below. 1. The following three entries are, respectively, the header row, a parent email, and a spreadsheet attachment: pBatesPre?xb?bBeginning Bates NumberprEnding Bates NumberprBeginning Bates RangeprEnding Bates Rangeb?pPage ExtensionpUbFile Createdb?bDate ith, John John Jane Doe, Markp?bp?bChecks .txtb?bh b?b00000002p 1b Receivable]: ?pSmith, John H.p?pSmith, John In globally de-duped productions there will be instances where production of documents from additional custodians will include documents previously produced. The two entries below are, respectively, the header row, and an overlay row producing a new custodian?s copy of an email previously produced: pBatesPre?xb?pBeginning Bates Numberb?pEnding Bates NumberprBeginning Bates RangeprEnding Bates Extensionb?pFile Createdp?pDate Receivedb?bTime hmidt, Jane