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Lohr v. Nissan North America, Inc

United States District Court, W.D. Washington

January 22, 2018

TAMARA LOHR and RAVIKIRAN SINDOGI, on behalf of themselves and all others similarly situated, Plaintiffs,
v.
NISSAN NORTH AMERICA, INC., and NISSAN MOTOR CO., LTD., Defendants. FIELD NAME DESCRIPTION

          TERRELL MARSHALL LAW GROUP PLLC, Beth E. Terrell, WSBA #26759, Gregory F. Coleman, Admitted Pro Hac Vice, GREG COLEMAN LAW PC, Charles Crueger, Admitted Pro Hac Vice, CRUEGER DICKINSON LLC, Edward A. Wallace, Admitted Pro Hac Vice, WEXLER WALLACE LLP, Attorneys for Plaintiffs

         SHOOK HARDY & BACON L.L.P., Heather A. Hedeen, WSBA #50687, Amir Nassihi, Admitted Pro Hac Vice, Andrew L. Chang, Admitted Pro Hac Vice, SHOOK HARDY & BACON L.L.P, William R. Sampson, Admitted Pro Hac Vice, SHOOK HARDY & BACON L.L.P, Attorneys for Defendant Nissan North America, Inc

          STIPULATION REGARDING DISCOVERY OF ELECTRONICALLY STORED INFORMATION AND ORDER

          RICARDO S. MARTINEZ CHIEF UNITED STATES DISTRICT JUDGE

         I. STIPULATION

         The parties hereby stipulate to the following provisions regarding the discovery of electronically stored information (“ESI”) in this matter:

         A. General Principles

         1. An 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.

         2. The 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.

         B. ESI Disclosures

         Within 45 days after the filing of the parties' Stipulation Regarding Discovery of Electronically Stored Information, each party shall disclose to the other:

         1. 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.

         2. Non-custodial Data Sources. A list of non-custodial data sources (e.g. shared drives, servers, databases, 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-based storage, cloud-based applications, cloud-based databases, social media accounts, messaging applications, 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 is not reasonably accessible under Fed.R.Civ.P. 26(b)(2)(B). Data sources listed below in Section C(3)(a) need not be included on this list.

         C. Preservation of ESI

         The parties acknowledge that they have a common law obligation to take reasonable and proportional steps to preserve discoverable information in the party's possession, custody or control. With respect to preservation of ESI, the parties agree as follows:

         1. Absent a showing of good cause by the requesting party, the parties shall not be required to modify the procedures used by them in the ordinary course of business to back-up and archive data; provided, however, that the parties shall preserve all discoverable ESI in their possession, custody or control.

         2. All parties shall supplement their disclosures in accordance with Rule 26(e) with discoverable ESI responsive to a particular discovery request or mandatory disclosure where that data is created after a disclosure or ...


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