1. On or before August 1, 2014, UMC is to provide the litigation hold letters it issued for the Clarity, GRASP, TeleTracking and CrimeStar systems. UMC is also to provide a declaration from the appropriate individual clarifying the structure and retention of the Siemen's database, including how it was verified and specifically what steps were taken to verify that it retains past versions of all policies and other responsive data. Mr. Edmondson is to provide a supplemental declaration that describes how the process he used to search the Siemen's database discovers records that contain responsive search terms. In addition, Mr. Schaibley is to provide his amended declaration addressing the issues identified by Special Master Garrie during the July 25, 2014 hearing. See 7/25/2014 Tr. 125:19–137:20. Mr. Mendoza is to provide a declaration that answers the following questions for each of the previously undisclosed timekeeping systems, Clarity, CrimeStar, TeleTracking, and GRASP:

• What is the retention schedule for each of the timekeeping systems?

• How far back does the data go for each of these timekeeping systems?

*2 • Can users delete data from any of the timekeeping systems? And, if so, which systems? Who is able to delete data from the systems? Once deleted, is the data gone permanently?

• Did Sodexo, its employees, or anyone else from UMC, or another third-party, delete data at any time from any of the timekeeping systems? Has data within them been moved, altered, lost, purged or destroyed in any way? If the answer is yes, include a description of what occurred and when.

• Did UMC at any point during the time period at issue migrate or upgrade the timekeeping systems? If yes, please include a statement that details when UMC performed the migration and what data they migrated and how it was migrated.

• How does the data entered by the users in each of the systems differ from data captured in Kronos? Please provide a statement for each system where the data differs that identifies the additional data that is captured in the timekeeping system that is not captured in Kronos.

• Is information on the duration of meal breaks available in the CrimeStar system? If this data is not available, what relevant data is captured by the system?

• For all the timekeeping systems, how long is the data kept that is entered by the users? Include the data retention policies for each of these systems. UMC is to also verify that the systems comply with the data retention policies and affirm this to Special Master Garrie.

• What does “[number] timesheets used and printed” mean within the Verification Report attached to Counsel Witty's 7/9/2014 email, “Small v. UMC: declaration of David Williams”? See Ex. C (7/9/2014 Witty email “Small v. UMC: declaration of David Williams”).

• What do the terms “Present” and “result” mean as those terms are used in Clarity user entries that were provided as sample data values by UMC? Include a statement that clarifies all the reports that Clarity can generate and UMC abilities to generate these reports.

• UMC is to provide a glossary to explain the field and column heading values for each type of report it submits for each of the timekeeping systems.

2. On or before August 4, 2014, UMC is to provide samples of all reports that can include lunch break data and materials showing what lunch break data is available through CrimeStar's RMS Report Creator Feature or through queries.[1] UMC is likewise to provide examples of all reports that can include lunch break data and the documentation for the TeleTracking Reports Module.[2]

3. On or before August 4, 2014, UMC is to have completed TIF production from the Q-drive.

4. On or before August 5, 2014, UMC is to produce responsive ESI from the third-party neutral complaint system operated by Global Compliance. UMC is to submit a statement affirming that all of the data has been preserved for the time period at issue.

5. On or before August 6, 2014, UMC is to provide further clarification as to the technical details of the three-cycle backup procedure for the timekeeping systems,[3] specifically:

• Whether data is stored for more than 28 days? And, if so, under what circumstances?

UMC is also to state the last backup they have of each of the timekeeping systems.

6. UMC is to provide custodian of records declarations within 72 hours of each document production going forward.

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Counsel Witty, also in her 7/9/2014 email, states that the sample report “was being provided as an example of the data available within CrimeStar.” The Crimestar Computer Aided Dispatch System Operations Manual (“CAD Manual”) states “Remember all Closed CAD event records are transferred into the RMS CFS where they can be searched or reported in a variety of ways.” CAD Manual, p. 84. The Crimestar System Administration and User Manual (“SAU Manual”) states that the “large number of reports available makes it impossible to describe each report in detail in this manual.” SAU Manual, p. 7–2. It also states that if “your normal query needs extend beyond the capabilities of Crimestar's Standard Query Features the following additional tools are suggested: • Use Crimestar's RMS Report Creator Feature (which is part of the Crimestar package).... Query results can be displayed or saved in many formats including reports, text, mail-merge files, spreadsheets, databases, and tabular on-screen views.” SAU Manual, p. 6–26.

As was the case with CrimeStar, Counsel Witty's cover email dated 7/8/2014, with the subject “Small v. UMC: Sample Report showing break times from TeleTracking System”, states that an attached report is “is being provided only as an example of the data available within the Teletracking system.” See Ex. D (7/8/2014 Witty email).

Counsel Witty's 7/29/2014 email “RE: Small v. UMC Updates” provided some additional information, but left some questions unanswered. See Ex. E (Witty's 7/29/2014 email “RE: Small v. UMC Updates).