Tentative Ruling

Pursuant to the stipulation of the parties this court is deciding the discovery issues currently brought before the court in defendant's Motion to Compel Further Responses to certain requests for production of documents (RFP). The stipulation encompassed an agreement to proceed on the protocol developed by the Civil Division to have discovery matters heard by "strike team" judges upon a streamlined process by judges on the strike team as opposed to the assigned IC Judge.

Defendant's Request for Further Responses to RFP's 1-3, 6-7, 9-15, 17-19, 21-24, 28-29, 33 and 35-92.

- Defendants RFP did not specify a manner of production for electronically stored information (ESI). During the meet and confer process, the plaintiff agreed to retain a forensic consultant to search for the relevant data mainly consisting of text messages, e-mails and social media account data. The production would include relevant meta data and plaintiff reserved the right to shift the cost to de