16. Entire Agreement. This Plan shall constitute the entire integrated agreement of the Parties. No prior or contemporaneous communications or prior drafts shall be relevant or admissible for purposes of determining the meaning or extent of any provisions herein. WHEREFORE, the Parties respectfully request that the Board, pursuant to Paragraph 13 of Order No. 1, issue an order governing the discovery of ESI that is consistent with the Plan set forth above. COMMONWEALTH OF PENNSYLVANIA ENVIRONMENTAL HEARING BOARD Appellant : : v. : EHB Docket No. ____ : DEPARTMENT OF : ENVIRONMENTAL PROTECTION : And Permittee [or Intervenor] : ORDER AND NOW, this _______ day of __________________, 201___, upon consideration of the Plan Concerning the Discovery of Electronically Stored Information (Electronic Discovery Plan) filed by the Parties, the filing is approved as the Electronic Discovery Plan for this case and all parties shall comply with its provisions. ENVIRONMENTAL HEARING BOARD ____________________________________ Judge DATED:___________________ c: For the Commonwealth of PA, DEP: For Appellant: For Permittee [or Intervenor]:
16. Entire Agreement. This Plan shall constitute the entire integrated agreement of the Parties. No prior or contemporaneous communications or prior drafts shall be relevant or admissible for purposes of determining the meaning or extent of any provisions herein. WHEREFORE, the Parties respectfully request that the Board, pursuant to Paragraph 13 of Order No. 1, issue an order governing the discovery of ESI that is consistent with the Plan set forth above. COMMONWEALTH OF PENNSYLVANIA ENVIRONMENTAL HEARING BOARD Appellant : : v. : EHB Docket No. ____ : DEPARTMENT OF : ENVIRONMENTAL PROTECTION : And Permittee [or Intervenor] : ORDER AND NOW, this _______ day of __________________, 201___, upon consideration of the Plan Concerning the Discovery of Electronically Stored Information (Electronic Discovery Plan) filed by the Parties, the filing is approved as the Electronic Discovery Plan for this case and all parties shall comply with its provisions. ENVIRONMENTAL HEARING BOARD ____________________________________ Judge DATED:___________________ c: For the Commonwealth of PA, DEP: For Appellant: For Permittee [or Intervenor]:
ESI_Sample_Plan_2.docx