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Rondevoo Technologies, LLC v. HTC America, Inc.

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

April 8, 2019

RONDEVOO TECHNOLOGIES, LLC, Plaintiff,
v.
HTC AMERICA, INC., Defendant.

          Nicholas Ranallo Nicholas Ranallo, Attorney at Law, Isaac Rabicoff Kenneth Matuszewski RABICOFF LAW LLC Counsel for Plaintiff, Rondevoo Technologies, LLC

          Ryan McBrayer Ryan McBrayer Perkins Coie LLP, Counsel for Defendant, HTC America, Inc.

          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

         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 ligation to cooperate in facilitating and reasonably limiting discovery requests and responses raises litigation costs and contributes to the risk of sanctions.

         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 response should be reasonably targeted, clear, and as specific as possible.

         B. LIAISON

         The parties have identified liaisons to each other who are and will be knowledgeable about and responsible for discussing their respective ESI. Each e-discovery liaison will be, or have access to those who are, knowledgeable about the technical aspects of e-discovery, including the location, nature, accessibility, format, collection, search methodologies, and production of ESI in this matter. The parties will rely on the liaisons, as needed, to confer about ESI and to help resolve disputes without court intervention.

         C. PRESERVATION

         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 responsible to a particular discovery request or mandatory disclosure where that data is created after a disclosure or response is made (unless excluded under (C)(3) below or any applicable privilege standard).

         3. Absent a showing of good cause by the requesting party, the following ...


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