It is therefore ORDERED that Victoria Manusos-Jenkins, on or before June 25, 2015, produce Responsive Electronically Stored Information (“ESI”), along with login credentials, from her electronic devices, which includes, but is not limited to, her iPhone 6, iPhone 5, iPad Mini, MacBook Air, the thumb drive containing information concerning Vestercorp, and any other electronic storage devices, which are identified in her deposition dated December 18, 2014 (the “Deposition”) to Protegga, LLC to take an image of these devices/accounts to conduct searches for ESI as set forth below. Additionally, Victoria Manusos-Jenkins will provide login credentials to Protegga, LLC for any cloud-based storage solution that may contain ESI (such as iCloud), and any web-based communication solution (such as Gmail, Facebook, and Linkedin accounts) that may contain ESI. Such examination shall be at the expense of Victoria Manusos-Jenkins, however, she may petition the Court for recovery of such expense.

“Responsive ESI” means any ESI which is:

Responsive ESI does not include any privileged communications of Victoria Manusos-Jenkins or communications involving claims related to Cause Number 296-54413-2012 in the 296th Judicial Court, Collin County, Texas which are not related to the causes of action asserted by Traxxas, LP in this proceeding.

Protegga, LLC shall conduct searches in the manner of a reasonably prudent forensic investigator, including searches for deleted information.

It is further ORDERED that once ESI is obtained from the devices and storage accounts, Julie Crawford, Esq. shall review the ESI for both privileged communication and relevancy. If there is a question regarding the relevancy of any ESI, Julie Crawford, Esq. shall produce such ESI to the Court for an in-camera inspection. At that time, the Court will determine if the ESI is Responsive ESI. Julie Crawford, Esq. shall prepare a Privilege Log for the ESI containing privileged communications. Subject to the above, all Responsive ESI shall be produced in accordance with the terms of this Order. Julie Crawford, Esq. shall produce Responsive ESI to Traxxas, LP on or before June 25, 2015 and any documents requiring an in-camera inspection to the Court on that date.

*2 It is further ORDERED that Victoria Manusos-Jenkins appear on July 7, 2015, at the United States District Court, Eastern District of Texas, 7940 Preston Rd, Plano, Texas 75024, at 9:00 a.m. for a deposition to occur in a room as directed by the Courtroom Deputy. This Order shall not affect Victoria Manusos-Jenkins' ability to object to any questions or areas of inquiry, or seek appropriate relief from questioning as provided by the Federal Rules of Civil Procedure.

It is further ORDERED that the relief granted in this Agreed Order disposes of all issues currently pending before the Court related to Plaintiff's Motion to Compel and for Sanctions (Dkt. 44) and Non-Party Victoria Manusos-Jenkins' Emergency Motion for Reconsideration of Order Granting in Part Motion to Compel and for Sanctions (Dkt. 94) and Motion to Stay Enforcement of Order Granting in Part Motion to Compel and for Sanctions (Dkt. 94)(Dkt. 95), excepting Traxxas may petition the Court to seek recovery of its attorneys' fees sought as provided in the Order (Dkt. 94).

SO ORDERED.

SIGNED this 18th day of June, 2015.