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Padilla v. U.S. Immigration and Customs Enforcement

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

May 7, 2019

YOLANY PADILLA, et al., Plaintiffs-Petitioners,
v.
U.S. IMMIGRATION AND CUSTOMS ENFORCEMENT, et al., Defendants-Respondents.

          MATT ADAMS, WSBA NO. 28287 LEILA KANG, WSBA NO. 48048 AARON KORTHUIS, WSBA NO. 53974 NORTHWEST IMMIGRANT RIGHTS PROJECT JOSEPH. H. HUNT ASSISTANT ATTORNEY GENERAL CIVIL DIVISION WILLIAM C. PEACHEY DIRECTOR, DISTRICT COURT SECTION OFFICE OF IMMIGRATION LITIGATION EREZ REUVENI ASSISTANT DIRECTOR, DISTRICT COURT SECTION

          TRINA REALMUTO* KRISTIN MACLEOD-BALL* AMERICAN IMMIGRATION COUNCIL *ADMITTED PRO HAC VICE ATTORNEYS FOR PLAINTIFFS-PETITIONERS

          ARCHITH RAMKUMAR NY BAR # 5269949 TRIAL ATTORNEY, DISTRICT COURT SECTION OFFICE OF IMMIGRATION LITIGATION CIVIL DIVISION ATTORNEYS FOR DEFENDANTS-RESPONDENTS

          AGREEMENT REGARDING DISCOVERY OF ELECTRONICALLY STORED INFORMATION AND ORDER

          Marsha J. Pechman United States Senior District Judge

         The Honorable Marsha J. Pechman

         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 date of submission of this order, 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 this information is within the custody and control of the party.

         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 ...


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