United States District Court, W.D. Washington, Seattle
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
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
J. Pechman United States Senior District Judge
Honorable Marsha J. Pechman
parties hereby stipulate to the following provisions
regarding the discovery of electronically stored information
(“ESI”) in this matter:
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.
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.
45 days after the date of submission of this order, or at a
later time if agreed to by the parties, each party shall
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
Non-custodial Data Sources. A list of non-custodial
data sources (e.g. shared drives, servers, etc.), if any,
likely to contain discoverable ESI.
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.
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 ...