40.262	Order to Establish Separate Document Depositories

It is ORDERED:

1.	Establishment of Depositories.1 Document depositories shall be established in       [specify city]     at such locations as the parties may agree on. In the absence of agreement, the court upon motion shall designate such locations. Documents produced by plaintiffs pursuant to formal or informal request shall be placed in a plaintiff’s depository maintained at the expense of plaintiffs; those produced by defendants pursuant to formal or informal request shall be placed in a defendant’s depository maintained at the expense of defendants. Each depository will contain equipment for producing copies and separately counting the copies that are made for each party. 
2.	Filing System. The ﬁling party shall place the documents in the depository in sequential order according to the document numbers, and the documents shall be organized in groups in accordance with the document identification prefixes. Documents without identification numbers shall be organized in an orderly and logical fashion. Existing English translations of all foreign-language documents shall be ﬁled with the documents.2
3.	Access, Copying, Log. Counsel appearing for any party in this litigation and the staffs of their respective law ﬁrms working on these cases shall have reasonable access during business hours to each document in any such depository and may copy or obtain copies at the inspecting party’s expense. Such inspection shall not be subject to monitoring by any party. A log will be kept of all persons who enter and leave the depository, and only duplicate copies of documents may be removed from the depository except by leave of court. [Access to, and copying of, confidential documents is subject to the limitations and requirements of the order protecting against unauthorized disclosure of such documents.]
4.	Subsequent Filings. After the initial deposit of documents in the depository, notice of all subsequent deposits shall be given to both liaison counsel.

Dated: 												
									United States District Judge

Notes:
	1.	This order contemplates creation of separate depositories for each side of the litigation. Consider whether the needs of the parties for separate facilities can also be accomplished through electronic means within a single facility. See order at supra section 40.261. 
	2.	Provision may be made for use of the most appropriate technology for storage, retrieval, and distribution of the documents, including electronic materials. See supra section 11.444.