The opinion of the court was delivered by: John M. Facciola U.S. Magistrate Judge
Having reviewed the Sedona Conference publication entitled "Best Practices for the Selection of Electronic Discovery Vendors: Navigating the Vendor Proposal Process" and the record herein, particularly our most recent conference with counsel, I have created a work plan that defines the ultimate goal of what we are trying to accomplish. I would ask counsel to review it carefully and, once they have, I will convene counsel by telephonic conference to hear their objections, additions, and suggestions as to the following:
I. Primary Goal: To create a system whereby all existing documents are hyper-linked to fields in a database that will permit the instantaneous retrieval from within the database of the information offered by plaintiffs in support of any factual proposition.
A. The system must be capable of being easily used by counsel and by the Court.
B. The requisite software must be made available to the Court.
C. The system must be entirely self-contained so that it can be used without reference to any other information to resolve the questions presented by each claim. To illustrate this requirement, we contemplate a database in which plaintiff could insert the hyperlinked evidence offered in support of a claim, the defendant could state its objection and, if need be, refer to hyper-linked evidence in contradiction or impeachment, and the Court would then provide its ruling. The following chart is a rough draft of the database system to be created:
Claim No. Dr. Date Plaintiff's evidence in support Defendant's objection and any countering evidence Court's ruling 123 Smith 10/02/01 Document or testimony Counter argument why evidence is insufficient; tender of countering evidence with explanation Claim sustained or denied, with reason
III. Requirements for Selection of Vendor:
A. Experience in similar situations.
B. Verified references from prior clients.
C. Ability to meet deadlines.
D. Sufficient hardware, software and personnel to perform task within deadlines set.
E. Information must be maintained with proper security and in compliance with any federal statutes or regulation pertaining to medical records and with any protective ...