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Verasonics, Inc. v. Supersonic Imagine, S.A.

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

May 2, 2018

VERASONICS, INC, Plaintiff,
v.
SUPERSONIC IMAGINE, S.A., Defendant.

          PACIFICA LAW GROUP LLP, Paul J. Lawrence, WSBA #13557 Kymberly K. Evanson, WSBA #39973 WALTERS WILSON LLP Erica D. Wilson (Admitted Pro Hac Vice) Eric S. Walters (Admitted Pro Hac Vice) Attorneys for Plaintiff Verasonics, Inc.

          MILLER NASH GRAHAM & DUNN LLP, Brian W. Esler, WSBA #22168 Kellen A. Hade, WSBA #44535 Attorneys for Defendant SuperSonic Imagine, S.A.

          AGREEMENT REGARDING DISCOVERY OF ELECTRONICALLY STORED INFORMATION AND ORDER

          Thomas S. Zilly, 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.

         3. Much of Defendant's information may be located in France, and Defendant asserts that it is subject to both French and European Union data protection directives and laws, including but not limited to the General Data Protection Regulation and French Blocking Statute. By entering into this Agreement, Defendant does not waive any of those protections or requirements.

         B. ESI Disclosures

         Within 53 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. 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). Section (C)(3)(a)(i) below sets forth data sources and ESI which are not ...


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