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To the extent the parties have made any agreements pursuant<br />

to Fed. R. Civ. P. 26(f)(3)(D) and Fed. R. Civ. P. 502(e)<br />

regarding a procedure to assert claims <strong>of</strong> privilege/protection<br />

after production and are requesting that the <strong>court</strong> include such<br />

agreement in an order, please set forth the agreement in detail<br />

below and submit a proposed order adopting the same.<br />

Seventh, in “12(B),” the Committee would change “Mediation” to “Court-<br />

Ordered Mediation subject to LCvR 16.3.”<br />

The new version <strong>of</strong> the “Joint Status Report and Discovery Plan” appears<br />

below at pages 29-32:<br />

28

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