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Matthew Edwards, Georgia Browne, and v. National Milk Federation Aka Cooperatives Working Together

April 17, 2013

MATTHEW EDWARDS, GEORGIA BROWNE, AND
TORAH MONTESSORI SCHOOL, INDIVIDUALLY AND ON BEHALF OF ALL OTHERS SIMILARLY SITUATED,
PLAINTIFFS,
v.
NATIONAL MILK FEDERATION AKA COOPERATIVES WORKING TOGETHER;
DAIRY FARMERS OF AMERICA, INC.;
LAND O'LAKES, INC.;
DAIRYLEA COOPERATIVE INC.; AND AGRI-MARK, INC.,
DEFENDANTS.



The opinion of the court was delivered by: Honorable Jeffrey S. White United States District Judge

CLASS ACTION JOINT STIPULATION AND PRODUCERS [PROPOSED] ORDER RE THE USE OF PREDICTIVE CODING TECHNOLOGY ACTION FILED: September 26, 2011

a Party) hereby stipulate, agree, and propose as follows: 3 documents collected from Land O'Lakes and have agreed that Land O' Lakes will utilize Recommind's Axcelerate software for its review workflow and production in this case. Axcelerate 15 incorporates predictive coding (also known as technology-assisted review) functionality, which Land O'Lakes will leverage for a more cost efficient and higher quality review. The Parties agree that the 17 following protocol will be followed to identify potentially responsive documents for review: possession, custody, or control of each custodian agreed upon by the Parties and in additional 20 locations under the possession, custody, or control of Land O'Lakes (such as shared drives or 21 departmental files) immediately upon entry of this order and isolate the document review corpus. 22

Land O'Lakes will generate an initial control set of documents. The control set will be a random, 24 statistically valid sampling of documents to estimate the number of responsive documents in the 25 corpus. The control set sample shall be determined using a 95% confidence level and 2% estimation 26 interval. The control set sample will then be reviewed for responsiveness and privilege, and Land 27 O'Lakes will provide Plaintiffs with a tracking report of the results of the control set generation and 28 review. At any point during the predictive coding process, Land O'Lakes' e-discovery liaison will

Plaintiffs and Defendant Land O'Lakes, Inc. (collectively "the Parties" and each, individually,

I.DEFINITIONS

A. "Document review corpus" refers to the body of documents remaining after the exclusion of known system files, incompatible file types (e.g., database files), duplicates, and documents that fall outside the agreed date range.

B. "Confidence level" means the statistical reliability of a result and in this instance refers to the likelihood that a measurement reached through sampling is accurate.

C. "Estimation interval" refers to the statistical error rate of a measured confidence level.

II.PROTOCOL

The Parties have discussed the methodologies or protocols for the search and review of 1. Step One -- Document Collection: Land O'Lakes will collect documents in the 2. Step Two -- Control Set: After loading the document review corpus into Axcelerate, meet and confer at Plaintiffs' request to discuss the results and method of the process. Land O'Lakes 2 agrees to confer in good faith regarding the incorporation of any input from Plaintiffs on the 3 application process. 4

5 during review of the control set will be included in an initial seed set, which will be used to train 6

Axcelerate to identify other potentially responsive documents in the document review corpus. The 7 seed set also will include responsive documents identified by Land O'Lakes through the use of search 8 and analytical tools, which will include the following: 9

b) The 500 most highly ranked1 responsive documents hit upon by an application of the

Boolean search terms selected by Land O'Lakes (listed in Appendix A), excluding documents already ...


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