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Espinoza v. City of Seattle

United States District Court, W.D. Washington, Seattle

January 26, 2018

DANIEL ESPINOZA, Plaintiff,
v.
THE CITY OF SEATTLE, WASHINGTON, and LIEUTENANT THOMAS MAHAFFEY, individually, Defendants.

          THOMAS G. JARRARD Law Office of Thomas G. Jarrard, PLLC Attorneys for Plaintiff.

          DAVID M. BOWMAN, Assistant City Attorney Seattle.

          AGREEMENT REGARDING DISCOVERY OF ELECTRONICALLY STORED INFORMATION AND [PROPOSED] ORDER

          THE HONORABLE JAMES L. ROBART, UNITED STATES DISTRICT JUDGE.

         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 30 days after the Rule 26(f) conference, or at a later time if agreed to by the parties, each party shall disclose:

         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, 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. Inacc ...


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