1 fPROPOSEDi ORDER

Defendants MJJ Productions, Tna. and MJJ Ventures, Inc.°s Notice of Motion and Motion
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3 to Compel Wade Robson's Compliance In Producing Documents and fox Sanctions(the

4 "Motion")came on for hearing on February 2,20i7. Howard Weitzman,Jonathan Steinsapir, and

5 Katherine Kieindienst from Kinsella Weitzman Iser Kump 8c Aldisert LLP appeared on behalf of
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6 Defendants MJJ Productions, Inc. and MJJ Ventures,Inc.("Defendants"}. Vince Finaldi and Alex
7 Canny appeared on behalfofPIaintzff Wade Robson("Robson"). The Court has reviewed the
8 papers associated with the Motion and the additional information and argument presented by
9 counsel at the time ofthe hearing. For good cause, the Court orders as follows:
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~o 1. Robson shall produce all responsive documents in his possession, custody, and

I1 cont~-o1 that he agxeed to produce in his June 3,2016 verified response and/or his July 26,2016
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12 verifed. amended response to the First Set ofRequests far Production of Documents and.Things
13 propounded by MJJ Productions, Ti c. on or befare March 1,2017(the "Production"~, including

X4 but not Limited to those documents described in Paragraphs 2 through S;
15 2. Robson shall search his previously produced emails to determine wYiether they have

1.5 attachments, detemune whether those attachments are available and accessible, and shall
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17 reproduce all previously produced emails that were missing attachments in full and complete form,

18 such that each email is produced together with its attaclunent(s};
19 3. Robson shall produce unredacted versions o~all responsive emails

20 to/from/cc'ed/bcc'ed to any members of his family (including, but not limited to parents,
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2l. grandparents, siblings, punts, uncles, cousins, and in-Laws);
22 4. Robson slxall produce unredacted versions of all responsive emails

23 ~ tolfrom/ce'ed/bce'ed to Helen Yu where a third party, who is not a lawyer, is the author or a
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24 recipient ofthe email, including but not limited to all emails to/from/cc'ed/bce'ed to Alan Nevins.

25 Communications exclusively between Robson and Helen Yu need not be provided;
25 5. Robson shall produce all drafts and versions of his book in their native file formats,

27 with all electronically stored information and metadata intact. The parties shall meet and confer
28 regarding payment for the production of electronically stored information and metadata;

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[PROPOSED)ORUBR-
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1 6. Robson shall prepare and sign a declaration detailing:(a} all steps lie took to search
2 for and locate responsive documents fox production;(b)the reasons for why soma emails(if any)
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3 produced by 3oey Robson(Rabson's mother)and Chantal Robson(Robson's sister), where
4 Robson is an author, recipient or is copied, have not been located; and(c)all steps,if any, he has
5 taken to preserve potentially responsive documents since the filing ofthis litigation. T~iis
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6 declaration shall be provided to Defendants with Rabson's Production;
7 7. Defendants' request for athird-party forensic examination ofRobson's aamputers,

8 davices, and accounts is denied without prejudice; and
Defendants' request for monetary sanctions is denied.
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9 8.
IO IT S4 ORDERED.
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DATED: ,2017
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14 THE HON.MITCHELL L. BECKLOFF
JUDGE OF THE SUPERIOR COURT
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APPROVED AS TO FORM ONLY BY:
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2I MANLY,STEWART &
KINSELLA WEITZMAN ISER KUMP &
22 ALDISERT,LLP
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E. Canny
24 Jonathan P. Steinsapir
Attorneys for Defendants Attorneys for F
zs MJJ Productions,Inc, and M3J Ventures, Inc. Wade Robsor~

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[PROPOSED]ORDER