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Schlumberger Technology Corporation, Inc., A v. East Charleston

December 9, 2011

SCHLUMBERGER TECHNOLOGY CORPORATION, INC., A TEXAS CORPORATION PLAINTIFF,
v.
EAST CHARLESTON, INC., A CALIFORNIA CORPORATION; PACIFIC AMERICAN MANAGEMENT COMPANY, A CALIFORNIA
LIMITED LIABILITY CORPORATION,
DEFENDANTS.



The opinion of the court was delivered by: Lucy H. Koh United States District Judge

RICHARD C. COFFIN (State Bar No. 70562); rcc@bcltlaw.com J. THOMAS BOER (State Bar No. 199563); jtb@bcltlaw.com LAURA S. BERNARD (State Bar No. 197556); lsb@bcltlaw.com BARG COFFIN LEWIS & TRAPP, LLP 350 California Street, 22nd Floor San Francisco, California 94104-1435 Telephone: (415) 228-5400 Fax: (415) 228-5450 Attorneys for Plaintiff

SCHLUMBERGER TECHNOLOGY CORPORATION, INC.

[PROPOSED] CASE MANAGEMENT ORDER NO. 2

AND RELATED ACTIONS

Plaintiff Schlumberger Technology Corporation ("STC"), defendants East Charleston, Inc. ("ECI") and Pacific American Management Company ("PAMCO"), and third party 22 defendant Fairchild Semiconductor Corporation (collectively "Parties") submit the following 23 proposed Case Management Order No. 2, consistent with the Parties' position in the Rule 26 24 Report and pursuant to the Court's orders at the November 22, 2011 Case Management 25 Conference and in the November 22, 2011 Minute Order and Case Management Order.

I. Discovery

A. Production of Documents, Including ESI

The Parties have agreed that each party producing documents in this case will produce a CD/DVD containing a digitized, searchable (i.e., optical character recognition) version of the 5 documents, imaged in single page TIFF format with document unitization and with industry-6 standard load files such as Opticon or IPRO LFP format with a delimited text file to indicate 7 where each document starts and stops. All documents produced by any party will be numbered 8 sequentially. Each party will choose a Bates prefix, consisting of uppercase letters, to be listed 9 before the Bates number for each document produced by that party. The image filename will 10 correspond with its Bates number. 11

apply to documents with a native format that prohibits printing on standard size paper (e.g., 13 audio, video, or oversized documents such as maps) or are requested in their native format (e.g., 14 Excel spreadsheets, AutoCAD, MODFLOW). Such documents will be produced in their native 15 format. The image filename of files produced in native format will correspond with the 16 respective assigned Bates numbers. Production of documents in native format does not preclude 17 a party from also producing those documents in TIFF format marked with Bates numbers if its 18 elects to do so. 19

20 documents that have otherwise been collected in electronic form (e.g., in ZIP files) will be 21 produced in the TIFF, Bates-numbered format, as described above, absent a particular need for 22 these documents in their original format. 23

The provisions of this section do not apply to documents received from third parties (including public agencies) or expert witnesses, to the extent such documents are produced. 25

1. Privilege Logs

In the event that any party withholds documents on the basis of privilege, that party will The requirement to produce a digitized version of documents in TIFF format will not Standard documents such ...


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