United States District Court, W.D. Washington, Seattle
Cantor LAW OFFICES OF CLIFFORD A. CANTOR, P.C.
Plaintiffs' Liaison Counsel.
POMERANTZ LLP Patrick V. Dahlstrom Leigh H. Smollar Omar
Jafri POMERANTZ LLP Jeremy A. Lieberman J. Alexander Hood II
Plaintiffs' Lead Counsel.
Gregory L. Watts Wilson Sonsini Goodrich & Rosati, P.C.
Nina F. Locker, pro hac vice Ignacio E. Salceda, pro hac vice
Joni Ostler, pro hac vice Daniel Slifkin, pro hac vice Karin
A. DeMasi, pro hac vice Lauren M. Rosenberg, pro hac vice
CRAVATH, SWAINE & MOORE LLP Counsel for Defendants Juno
Therapeutics, Inc., Hans E. Bishop, Steven D. Harr, and Mark
STIPULATION REGARDING DISCOVERY OF ELECTRONICALLY
STORED INFORMATION AND ORDER
RICARDO S. MARTINEZ CHIEF UNITED STATES DISTRICT JUDGE.
parties hereby stipulate to the following provisions
regarding the discovery of electronically stored information
(“ESI”) in this matter:
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 cooperate in
facilitating and reasonably limiting discovery requests and
responses raises litigation costs and contributes to the risk
proportionality standard set forth in Fed.R.Civ.P. 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.
August 14, 2017, each party shall disclose:
1. Custodians. The 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
2. Non-custodial Data Sources. A list of
non-custodial data sources (e.g. shared drives, servers,
etc.), if any, likely to contain discoverable ESI.
3. 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.
4. 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