United States District Court, W.D. Washington, Seattle
TERRELL MARSHALL LAW GROUP PLLC Beth E. Terrell, WSBA #26759
Blythe H. Chandler, WSBA #43387 Elizabeth A. Adams, WSBA
#49175 Sam Leonard, WSBA #46498 LAW OFFICE OF PAUL ARONS
Attorneys for Plaintiffs
ROTHWELL EARLE & XOCHIHUA, P.C. Suzanne Pierce, WSBA
#22733 Patrick Rothwell, WSBA #23878 Keith M. Liguori, WSBA
#51501 Attorneys for Defendant J. Michael Unfred, d/b/a J.
Michael Unfred LLC
LAW, LLC Jeffrey I. Hasson, WSBA #23741 Attorney for
Defendants CSO Financial, Inc. and Mary Inscore
C. COUGHENOUR UNITED STATES DISTRICT JUDGE
matter comes before the Court on the parties' agreement
regarding discovery of electronically stored information
(ESI) (Dkt. No. 13). The parties hereby stipulate to the
attorney's zealous representation of a client is not
compromised by conducting discovery in a cooperative manner.
The failure of counsel or the parties to litigation to
cooperate in facilitating and reasonably limiting discovery
requests and responses raises litigation costs and
contributes to the risk of sanctions.
proportionality standard set forth in Federal Rule of Civil
Procedure 26(b)(1) must be applied in each case when
formulating a discovery plan. To further the application of
the proportionality standard in discovery, requests for
production of ESI and related responses should be reasonably
targeted, clear, and as specific as possible.
30 days after the Rule 26(f) conference, or at a later time
if agreed to by the parties, each party shall disclose:
Custodians. The five custodians most likely to have
discoverable ESI in their possession, custody, or control.
The custodians shall be identified by name, title, connection
to the instant litigation, and the type of the information
under his/her control.
Non-custodial Data Sources. A list of non-custodial
data sources (e.g. shared drives, servers, etc.), if any,
likely to contain discoverable ESI.
Third-Party Data Sources. A list of third-party data
sources, if any, likely to contain discoverable ESI (e.g.
third-party email and/or mobile device providers,
“cloud” storage, etc.) and, for each such source,
the extent to which a party is (or is not) able to preserve
information stored in the third-party data source.
Inaccessible Data. A list of data sources, if any,
likely to contain discoverable ESI (by type, date, custodian,
electronic system or other criteria sufficient to
specifically identify the data source) that a party asserts
is not ...