Legal Production Request

LEGAL PRODUCTION REQUEST

This Legal Production Request (the Request) is made on Date: by Requesting Party: and is directed to Producing Party: for documents and electronically stored information related to Matter/Cause: filed with Tribunal/Court/File No.: .

RECITALS

WHEREAS, Requesting Party reasonably believes that Producing Party has in its possession, custody or control certain Documents and Electronically Stored Information that are relevant to the claims and defenses in the matter identified above; and

WHEREAS, Requesting Party seeks the production of those Documents and Electronically Stored Information in a form and manner that preserves source metadata and facilitates review and, where appropriate, the protection of privileged or confidential information; and

WHEREAS, the parties desire to set forth agreed terms, timelines and protocols governing the scope, format and logistics of production to minimize disputes and preserve rights.

NOW, THEREFORE, in consideration of the mutual promises and covenants set forth herein, the parties agree as follows:

1. DEFINITIONS

For the purposes of this Request: (a) "Document(s)" shall mean all writings, recordings, photographs, files, emails, attachments, databases, logs, metadata, and other tangible or electronic records within the custody or control of Producing Party; (b) "Electronically Stored Information" or "ESI" includes email, databases, files, metadata, server logs, backups, and any other material stored in electronic form; and (c) "Confidential Information" means information entitled to protection from public disclosure under applicable law or by agreement of the parties.

2. SCOPE OF REQUEST

Producing Party is requested to produce all non-privileged Documents and ESI responsive to the categories described below that are in its possession, custody, or control, including Documents in the possession of its agents, contractors, and third-party service providers, for the date range From: To: .

3. CUSTODIANS, SOURCES, AND SEARCH PROTOCOL

4. PRODUCTION FORMAT AND TECHNICAL REQUIREMENTS

Unless otherwise agreed, Producing Party shall produce Documents in the following formats and with the following metadata fields:

Native/Original electronic format    Text-searchable PDF    Single-page TIFF    Accompanying extracted text/utility files

Producing Party shall preserve and produce metadata fields including but not limited to: file name, original path, custodian, creation/modification dates, author/sender, recipients, and hash values. Bates numbering, load files, and cross-reference files shall be provided with productions where applicable.

5. PRIVILEGE, REDACTION AND PRIVILEGE LOG

Producing Party may redact or withhold only those portions of Documents that are privileged or otherwise protected. Any withheld or redacted Documents shall be logged in a privilege log that identifies, at a minimum, document identifier, date, author/sender, recipient(s), a brief description of the nature of the withheld material, and the asserted privilege or protection.

Assertion of privilege shall be governed by the applicable rules of procedure and any court order. The parties agree to a clawback protocol under which the inadvertent production of privileged material will not constitute a waiver if produced in error and notice is promptly provided.

6. TIMELINE, MEET AND CONFER, AND COSTS

Prior to any motion practice, the parties shall meet and confer in good faith to resolve disputes arising from this Request. The parties shall hold an initial meet-and-confer conference on or before Date: to address scope, search methodology, and production logistics.

Unless otherwise agreed, each party shall bear its own costs of collection and review. If Producing Party seeks cost-shifting, it shall provide a written proposal identifying specific costs and reasonable justification for shifting.

7. OBJECTIONS AND RESERVATION OF RIGHTS

Producing Party shall state any objections to specified categories of Documents within Number of Days: days of service of this Request. An objection must identify the specific category objected to and the factual or legal basis for the objection. Failure to object timely shall be deemed a waiver of such objection.

Nothing in this Request waives any party's right to seek protective orders, to contest relevance, to assert privileges, or to seek under-seal treatment for confidential materials.

8. CERTIFICATION

The undersigned Requesting Party certifies that the information provided in this Request is complete and accurate to the best of its knowledge, that the Request is reasonable in scope and directed to relevant sources, and that prior to serving this Request the undersigned attempted to meet and confer in good faith with Producing Party regarding scope and procedures.

9. NOTICES

All notices required or permitted under this Request shall be in writing and delivered to the addresses and contacts set forth below, and shall be effective upon receipt.

10. MISCELLANEOUS

Governing Law: This Request shall be governed by and construed in accordance with the laws of the jurisdiction in which the tribunal or court identified above sits, without regard to conflict of law principles.

Entire Agreement: This Request constitutes the entire agreement between the parties with respect to the subject matter herein and supersedes all prior oral or written communications on the same subject.

Severability: If any provision of this Request is held to be invalid or unenforceable, the remainder shall continue in full force and effect.

Amendments; Waiver: No amendment to this Request shall be effective unless made in writing and signed by both parties. No waiver of any provision hereof shall be effective unless in writing and signed by the party granting such waiver.

Counterparts: This Request may be executed in counterparts, each of which shall be deemed an original and all of which together shall constitute one and the same instrument.

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