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Chen v. D'Amico

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

February 14, 2018

SUSAN CHEN, et. al., Plaintiffs,
v.
NATALIE D'AMICO, et al., Defendants.

          Shawn Larsen-Bright, Nathan Alexander, Geoff J. M. Bridgman, T. Daniel F. Shickich, Sarah Cox, Counsel for Defendants Attorneys for Plaintiff Susan Department, Ron Gibson, and Kristi Wilson Chen, individually, and as FRCP 17 Guardian Ad Litem for Plaintiff JL

          Aaron P. Riensche, Augustine Lo, Counsel for Defendants City of Redmond,

          Michael David Myers, Attorneys for Plaintiff Naixiang Lian

          Scott M. Barbara, Counsel for DSHS, Kimberly Danner, Litem for Plaintiff LLTimothy Earwood, Jill Kegel, Bill Moss, Kevin Quigley, and Tom Soule

          MODEL AGREEMENT REGARDING DISCOVERY OF ELECTRONICALLY STORED INFORMATION AND ORDER

          THE HONORABLE JAMES L. ROBART UNITED STATES DISTRICT COURT 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 this Order is entered, 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 ...

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