United States District Court, W.D. Washington, Seattle
POWELL PC D. Michael Reilly Attorneys for Defendant Fred
Hutchinson Cancer Research Center
LAW Group, PLLC Peter Montine Attorney for Plaintiff Jon
C. COUGHENOUR UNITED STATES DISTRICT JUDGE.
matter comes before the Court on the parties' stipulated
motion regarding the discovery of electronically stored
information (“ESI”) (Dkt. No. 28). Pursuant to
the parties' stipulation, the Court ORDERS the following:
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 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.
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
a. Jon Flowers, Plaintiff. Emails and documents.
a. Jon Flowers, Employee Relations Supervisor, Plaintiff. Mr.
Flowers emails ...