Search Terms, Culling Criteria, and Review Methodology. Each Producing Party shall design and implement the methods it uses to identify, cull and review its potentially responsive ESI based on its knowledge and understanding of its own data, the facts and issues involved in this action, and the Receiving Party’s document requests. Each Producing Party has the right to craft and identify search terms, utilize predictive coding, apply filters, or apply other analytics to identify and review potentially responsive ESI. A Producing Party may apply search terms to custodial documents and may also conduct a targeted collection of a Custodian’s non-email custodial ESI or Non-Custodial Sources by identifying sources likely to contain responsive materials (e.g. file folders on a given hard drive).
