

Search for the name of defendant Vainer in the accounts of the designated custodians other than Vainer for the period from Apthrough FebruJudge Mann stated: “Mr.Arboleda’s name in conducting the keyword search of her email account.” That said, in order to reduce the chance of unresponsive ‘hits,’ the Niyazov defendants need not conduct a search for Ms. For the period from Apto February 14, 2020, a search for the names of five individuals who were identified in the parties’ Rule 26 initial disclosures Judge Mann stated: “Again, the Niyazov defendants’ cries of undue burden are purely speculative, in that they do not appear to have performed a search to generate a ‘hit report’ that reflects the number of emails that would have to be reviewed or subjected to predictive coding.Plaintiffs’ proposed search of emails, on 18 specific dates, for plaintiffs’ names, or for the terms “legal assistant,” “assistant,” “paralegal,” and “secretary” Judge Mann stated: “To the extent that the Niyazov defendants argue that these terms are too generic, their position is inconsistent with other search terms to which they have agreed, e.g., “employee,” “dinner,” and “restaurant.”…The search terms “legal assistant,” “assistant,” “paralegal,” and “secretary” are relevant to plaintiffs’ employment status and thus to identifying their employer(s).”.Judge Mann ruled on six search term requests, as follows: The Court further directed the parties to confer regarding the selection of search term requests and a stipulated ESI protocol, and to file a joint status report by October 15th, but the parties jointly advised they were at an impasse as to the search term requests (with the Niyazov defendants calling them “broad and non-specific”) and the format in which the resulting ESI must be produced. At a conference held on October 12, 2021, the Court granted plaintiffs’ motion to compel in large part and directed the Niyazov defendants to “conduct a search for electronic documents and information relevant to plaintiffs’ claims of sexual harassment and failure to pay wages, including information regarding plaintiffs’ employment status”, from several custodians. In this case involving sexual harassment claims against the defendants, the plaintiffs moved to compel the production of electronic communications from the Niyazov defendants on October 4, 2021. Mann, responding to a joint request by the plaintiffs and the Niyazov defendants to resolve discovery disputes, granted the plaintiffs’ demands in large part, requiring the Niyazov defendants to conduct a search of ESI using additional search term requests proposed by plaintiffs and requiring the Niyazov defendants to produce the resulting ESI in a text-searchable format, but stating the Niyazov defendants “need not produce metadata”.

12, 2021), New York Magistrate Judge Roanne L.
