Certification Of Corporation Case Study

870 Words 4 Pages
1. Certification of Conference. Pursuant to Fed. R. Civ. P. 26(f), a meeting was held on February 22, 2016 at 12:00PM Eastern Standard Time and was conducted by the undersigned counsel for the designated parties in the above captioned case.

2. Brief Statement of the Nature and Complexity of the Case. XYZ, Incorporated (“XYZ”) manufactures custom medical devices that are used in delicate surgeries. The devices cost about $95,000.00 apiece and are manufactured to order with very short notice. ABC Corporation (“ABC”) purchases the medical devices from XYZ at wholesale prices and sells them at retail prices to hospitals and surgeons.

On December 15, 2014, ABC received a voice mail from a surgeon requesting a 20” x15” device.
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Form of production: All electronically stored information shall be delivered in a common digital format and readable by either Windows or Mac operating systems. All electronically stored information not currently in a common digital format and readable by either Windows or Mac operating systems shall be converted to a common digital format that is readable by either Windows or Mac operating system. Electronically stored information located on “SuperMax” servers shall be collected and delivered in the manner determined by a licensed “SuperMax” specialist.

ii. Distribution of costs: Plaintiff shall be responsible for twenty-five percent of all costs associated with the production of the requested electronically stored information. Defendant shall be responsible for seventy-five percent of all costs associated with the production of the requested electronically stored information. Plaintiff and Defendant agree that Defendant is in a better position to handle the higher percentage of production costs. Plaintiff and Defendant agree that the nature of Defendant’s complex computer and data systems warrant Defendant’s larger share of the production
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Plaintiff will provide all emails and voicemails occurring between directors, officers, management, employees, relevant customers, relevant business partners, and any individual reasonably related to ABC Corporation’s business.
2. Plaintiff will work to collect and provide all information under the control of Bill, a past ABC Corporation employee.
3. Plaintiff will provide access to its servers in North Beach, Miami, Florida and Charlotte, North Carolina.

Defendant agrees to the production of the following:

1. Defendant will provide access to its “SuperMax” servers and provide a licensed specialist to assist in retrieving and gathering all relevant data stored on its “Supermax” servers.
2. Defendant will provide all emails from all offices and all personnel, including, but not limited to, those occurring during the month of December 2015.
3. Defendant will provide all voicemails from all offices and all personnel, including, but not limited to, those occurring during the month of December 2015.

4. The parties cannot reach agreement and seek relief from the Court on the following issues:

Plaintiff disagrees to the production of the following:

1. All backup

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