Van Wagner et al v. Court of Master Sommeliers, Americas et al

VAN WAGNER ET AL v CMS-A – SEARCH TERM CHART
VAN WAGNER ET AL v CMS ET AL - SEARCH TERM CHART 02-17-26(112951571.1) (002) - 2/18/2026 9:33 AM
Proposed Term Agree
Y/N
Plaintiffs’ Position Defendant’s Position Court
Order
(Y/N)
Youngs Y Mr. Narito’s employer, Young’s Market, who is believed to
have offered to provide CMS with Mr. Narito’s emails.
Agree.
Youngsmarket Y Mr. Narito’s employer, Young’s Market, who is believed to
have offered to provide CMS with Mr. Narito’s emails.
“Youngsmarket” is the email extension for Mr. Nartio’s
email address. It is relevant.
Agree.
Julie Dalton N Ms. Dalton is one of the individuals who received Mr.
Narito’s email in this case. Mention of her name in the
relevant time period would be relevant.
Plaintiff Agrees to limit time period from 2018 until
completion of the review of the investigation (through 2022)
Dalton + 2018 + Exam for 2018-present
Active member that teaches 15 courses per year. Must be
limited to 2018 Wine Tasting Exam or at least 2018 to 2020
time period.
Robert Ord Y Mr. Ord is one of the individuals who received Mr. Narito’s
email in this case. Mention of his name in the relevant time
period would be relevant. Also, Mr. Ord sent letters to CMS
regarding the Exam and a lawsuit.
Agree.
Elton Nichols Y Mr. Nichols is one of the individuals who received Mr.
Narito’s email in this case. Mention of his name in the
relevant time period would be relevant.
Agree.
Troy Smith Y Mr. Smith is one of the individuals who is believed to have
received Mr. Narito’s email in this case. Mention of his
name in the relevant time period would be relevant.
Agree.
Investigation +
Exam
N This term in the context of the time period is likely to
produce only relevant hits.
Disagree. The time-period is roughly 8 years. The subject
matter is limited to the tasting portion of the master sommelier
exam. This will result in an excessive amount of irrelevant hits
and cause delays. The term should be limited to 2018 tasting
exam.
Investigate +
Exam
N This term in the context of the time period is likely to
produce only relevant hits.
Disagree. The time-period is roughly 8 years. The subject
matter is limited to the tasting portion of the master sommelier
exam. This will result in an excessive amount of irrelevant hits
and cause delays. The term should be limited to 2018 tasting
exam.
Yes
through
2022
("YT22")
YT22
YT22
DISCOVERY ORDER February 19, 2026 /s/ Thomas S. Hixson, U.S.M.J.	
Case 3:22-cv-05001-EMC Document 137 Filed 02/19/26 Page 1 of 7

VAN WAGNER ET AL v CMS-A – SEARCH TERM CHART
VAN WAGNER ET AL v CMS ET AL - SEARCH TERM CHART 02-17-26(112951571.1) (002) - 2/18/2026 9:33 AM
Proposed Term Agree
Y/N
Plaintiffs’ Position Defendant’s Position Court
Order
(Y/N)
Invalidation N This term in the context of the time period is likely to
produce only relevant hits.
Disagree. The time-period is roughly 8 years. The subject
matter is limited to the tasting portion of the master sommelier
exam. This will result in an excessive amount of irrelevant hits
and cause delays. The term should be limited to 2018 tasting
exam.
Invalidate N This term in the context of the time period is likely to
produce only relevant hits.
Disagree. The time-period is roughly 8 years. The subject
matter is limited to the tasting portion of the master sommelier
exam. This will result in an excessive amount of irrelevant hits
and cause delays. The term should be limited to 2018 tasting
exam.
Richard Betts N Mr. Betts was in active communication with CMS about the
investigation; this term in the context of the time period is
likely to produce only relevant hits.
Mr. Betts is not an active member. Agree to limit relevant
time through 2022
Disagree. Active member involved in with exams and programs
and logistics. Must be limited to 2018 Wine Tasting Exam or a
period 2018 to 2020.
Bobby Stuckey N Mr. Stuckey was in active communication with CMS about
the investigation; this term in the context of the time period
is likely to produce only relevant hits.
Agree to limit relevant time through 2022
Disagree. Active member involved in with exams and programs
and logistics. Must be limited to 2018 Wine Tasting Exam or a
period 2018 to 2020.
Jay Fletcher N Mr. Fletcher was in active communication with CMS about
the investigation; this term in the context of the time period
is likely to produce only relevant hits.
Agree to limit relevant time through 2022
Disagree. Active member involved in with exams and programs
and logistics. Must be limited to 2018 Wine Tasting Exam or a
period 2018 to 2020.
Dustin Wilson N Mr. Wilson was in active communication with CMS about
the investigation; this term in the context of the time period
is likely to produce only relevant hits.
Agree to limit relevant time through 2022
Disagree. Active member involved in with exams and programs
and logistics. Must be limited to 2018 Wine Tasting Exam or a
period 2018 to 2020.
Andrea Robinson N Ms. Robinson was in active communication with CMS about
the investigation; this term in the context of the time period
is likely to produce only relevant hits.
Agree to limit relevant time through 2022
Disagree. Active member involved in with exams and programs
and logistics. Must be limited to 2018 Wine Tasting Exam or a
period 2018 to 2020.
YT22
YT22
YT22
YT22
YT22
YT22
YT22
Case 3:22-cv-05001-EMC Document 137 Filed 02/19/26 Page 2 of 7

VAN WAGNER ET AL v CMS-A – SEARCH TERM CHART
VAN WAGNER ET AL v CMS ET AL - SEARCH TERM CHART 02-17-26(112951571.1) (002) - 2/18/2026 9:33 AM
Proposed Term Agree
Y/N
Plaintiffs’ Position Defendant’s Position Court
Order
(Y/N)
Tasting + narito Y This term in the context of the time period is likely to
produce only relevant hits.
Agree.
Png Y/N “png” was in the key email in this case and documents
containing it will be relevant. CMS/ its IT provider can
exclude file extensions from its searching.
To the extent that file extensions can be excluded, the Agree. If
not, disagree.
Cdp Y “cdp” was in the key email in this case and documents
containing it will be relevant.
Agree.
Narito Y Was defendant in this case, any information containing his
name is relevant.
Agree.
Dan Pilkey Y Plaintiff in this case, any information containing his name is
relevant.
Agree.
Peter Bothwell Y Plaintiff in this case, any information containing his name is
relevant.
Agree.
Greg Van
Wagner
Y Plaintiff in this case, any information containing his name is
relevant.
Agree.
Allegation(s) +
exam
N This term in the context of the time period is likely to
produce only relevant hits.
Disagree. The time-period is roughly 8 years. The subject
matter is limited to the tasting portion of the master sommelier
exam. This will result in an excessive amount of irrelevant hits
and cause delays. The term should be limited to 2018 tasting
exam.
Litigation + Exam N This term in the context of the time period is likely to
produce only relevant hits.
Disagree. The time-period is roughly 8 years. The subject
matter is limited to the tasting portion of the master sommelier
exam. This will result in an excessive amount of irrelevant hits
and cause delays. The term should be limited to 2018 tasting
exam.
Jfletch + exam Y This term in the context of the time period is likely to
produce only relevant hits.
Agree.
Decision + exam N This term in the context of the time period is likely to
produce only relevant hits.
Disagree. The time-period is roughly 8 years. The subject
matter is limited to the tasting portion of the master sommelier
exam. This will result in an excessive amount of irrelevant hits
and cause delays. The term should be limited to 2018 tasting
exam.
Hearing + exam N This term in the context of the time period is likely to
produce only relevant hits.
Disagree. The time-period is roughly 8 years. The subject
matter is limited to the tasting portion of the master sommelier
Yes if fileextensions can be excluded
YT22
YT22
No
YT22
Case 3:22-cv-05001-EMC Document 137 Filed 02/19/26 Page 3 of 7

VAN WAGNER ET AL v CMS-A – SEARCH TERM CHART
VAN WAGNER ET AL v CMS ET AL - SEARCH TERM CHART 02-17-26(112951571.1) (002) - 2/18/2026 9:33 AM
Proposed Term Agree
Y/N
Plaintiffs’ Position Defendant’s Position Court
Order
(Y/N)
exam. This will result in an excessive amount of irrelevant hits
and cause delays. The term should be limited to 2018 tasting
exam.
Ethics N This term in the context of the time period is likely to
produce only relevant hits.
Disagree. The time-period is roughly 8 years. The subject
matter is limited to the tasting portion of the master sommelier
exam. This will result in an excessive amount of irrelevant hits
and cause delays. The term should be limited to 2018 tasting
exam.
2018 examination N This term in the context of the time period is likely to
produce only relevant hits.
Disagree. CMS conducts more than 100 exams per year and
receives numerous emails per exam worldwide. The time-
period is roughly 8 years. The subject matter is limited to the
tasting portion of the master sommelier exam. This will result in
an excessive amount of irrelevant hits and cause delays. The
term should be limited to 2018 MS tasting exam.
Tasting portion +
2018
Y This term in the context of the time period is likely to
produce only relevant hits.
Agree.
Misconduct N This term in the context of the time period is likely to
produce only relevant hits.
Disagree. The term should be excluded or otherwise be limited
to alleged allegations of the 2nd Amended Complaint such as
communications related to alleged sexual misconduct by the
former board members during 2018 time period when the
decision to investigate or invalidate was being made.
Alleged misconduct that occurred after the decision would not
be relevant and would waste time and money and potentially
lead to withholding countless documents. Members that were
not involved in the investigation should not be involved.
Member conduct
+ exam
N This term in the context of the time period is likely to
produce only relevant hits.
Disagree. This should not be a search term. It does not make
sense and is not relevant. Further, The time-period is roughly 8
years. The subject matter is limited to the tasting portion of the
master sommelier exam. This will result in an excessive amount
of irrelevant hits and cause delays. The term should be limited
to 2018 tasting exam, if not excluded.
No
YT22
YT22
YT22
+ exam
Case 3:22-cv-05001-EMC Document 137 Filed 02/19/26 Page 4 of 7

VAN WAGNER ET AL v CMS-A – SEARCH TERM CHART
VAN WAGNER ET AL v CMS ET AL - SEARCH TERM CHART 02-17-26(112951571.1) (002) - 2/18/2026 9:33 AM
Proposed Term Agree
Y/N
Plaintiffs’ Position Defendant’s Position Court
Order
(Y/N)
Suspension N This term in the context of the time period is likely to
produce only relevant hits.
Disagree. The time-period is roughly 8 years. The subject
matter is limited to the tasting portion of the master sommelier
exam. This will result in an excessive amount of irrelevant hits
and cause delays. The term should be limited to 2018 tasting
exam.
Expulsion N This term in the context of the time period is likely to
produce only relevant hits.
Disagree. The term should be excluded. Plaintiffs were never
expelled from anything. To the extent used it should be limited
to 2018 wine tasting portion of the exam.
Kith N Kith was CMS’ PR firm hired only for the 2018 Exam issue;
this term in the context of the time period is likely to
produce only relevant hits.
Disagree. Kith is a PR firm that has already been subpoenaed.
In any event, to the extent the term is not excluded, the time-
period is roughly 8 years. The subject matter is limited to the
tasting portion of the master sommelier exam. This will result in
an excessive amount of irrelevant hits and cause delays. The
term should be limited to 2018 tasting exam.
Coletti N Bill Coletti worked for Kith (the PR firm) and was only
involved in the 2018 Exam issue; this term in the context of
the time period is likely to produce only relevant hits.
Disagree. Kith is a PR firm that has already been subpoenaed.
In any event, to the extent the term is not excluded, the time-
period is roughly 8 years. The subject matter is limited to the
tasting portion of the master sommelier exam. This will result in
an excessive amount of irrelevant hits and cause delays. The
term should be limited to 2018 tasting exam.
Audit + exam N This term in the context of the time period is likely to
produce only relevant hits.
Disagree. The term does not make sense. There was no audit
at issue in this matter. To the extent the term is not excluded,
the time-period is roughly 8 years. The subject matter is limited
to the tasting portion of the master sommelier exam. This will
result in an excessive amount of irrelevant hits and cause
delays. The term should be limited to 2018 tasting exam. CMS
conducts over a 100 exams per year which are audited.
Committee +
exam
N This term in the context of the time period is likely to
produce only relevant hits.
Disagree. The term does not make sense. There was a special
committee in 2018 that was involved in investigating the exam.
To the extent not excluded then the term should be limited to
special committee and 2018 wine tasting portion of the exam.
Re-test N This term in the context of the time period is likely to
produce only relevant hits.
Disagree. Plaintiffs’ re-testing of the exam is not at issue.
Further, Plaintiff’s names are already be searched. The term
should be excluded.
YT22
YT22
YT22
YT22
No
YT22
No
+ (membership
or member)
+ exam
Special
Case 3:22-cv-05001-EMC Document 137 Filed 02/19/26 Page 5 of 7

VAN WAGNER ET AL v CMS-A – SEARCH TERM CHART
VAN WAGNER ET AL v CMS ET AL - SEARCH TERM CHART 02-17-26(112951571.1) (002) - 2/18/2026 9:33 AM
Proposed Term Agree
Y/N
Plaintiffs’ Position Defendant’s Position Court
Order
(Y/N)
Tasting + 2018 N This term in the context of the time period is likely to
produce only relevant hits.
Disagree. The term should be limited to MS exam.
Due process N This term in the context of the time period is likely to
produce only relevant hits.
Disagree. The time-period is roughly 8 years. The subject
matter is limited to the tasting portion of the master sommelier
exam. This will result in an excessive amount of irrelevant hits
and cause delays. The term should be limited to 2018 tasting
exam.
2018 Tasting
Master
Sommelier Exam
Y Defendant contends that in order to search for, review and
produce documents in less than two weeks which is not the
time typically allowed for a document production, the following
search terms should be the only search terms used. Defendant
again requests that CMS be allowed to conduct it own
searches.
2018 Tasting
Master
Sommelier Exam
Board Minutes
Y See Above.
2018 Tasting
Master
Sommelier Exam
Invalidation
Y See Above.
2018 Tasting
Master
Sommelier Exam
Notice to
Candidates of
Invalidation
Y See Above.
2018 Tasting
Master
Sommelier Exam
Wine Tasting
Investigation
Y See Above.
2018 Tasting
Master
Sommelier Exam
Hearing
Y See Above.
YT22
YT22
+ exam
+ 2018
Case 3:22-cv-05001-EMC Document 137 Filed 02/19/26 Page 6 of 7

VAN WAGNER ET AL v CMS-A – SEARCH TERM CHART
VAN WAGNER ET AL v CMS ET AL - SEARCH TERM CHART 02-17-26(112951571.1) (002) - 2/18/2026 9:33 AM
Case 3:22-cv-05001-EMC Document 137 Filed 02/19/26 Page 7 of 7