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S&W Forest Products Ltd. v. Cedar Shake & Shingle Bureau

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

May 22, 2019

S&W FOREST PRODUCTS, LTD., a British Columbia corporation, Plaintiff,
v.
CEDAR SHAKE & SHINGLE BUREAU, a Washington nonprofit corporation; WALDUN FOREST PRODUCTS LTD., a British Columbia corporation; and ANBROOK INDUSTRIES LTD., a British Columbia corporation, Defendants.

          HAGLUND KELLEY LLP Michael E. Haglund, OSB No. 772030 Michael K. Kelley, OSB No. 853782 Eric J. Brickenstein, OSB No. 142852 JAMESON BABBITT STITES & LOMBARD Bruce P. Babbitt, WSBA No. 4830 LOCAL COUNSEL Attorneys for Plaintiff

          LANE POWELL PC Larry S. Gangnes Larry S. Gangnes, WSBA No. 08118 Heidi B. Bradley, WSBA No. 35759 Jessica N. Walder, WSBA No. 47676 Joseph D. Adamson, WSBA No. 54752 Attorneys for Cedar Shake and Shingle Bureau

          YARMUTH LLP Molly A. Terwilliger Molly A. Terwilliger, WSBA No. 28449 Elizabeth S. Weinstein Attorneys for Anbrook Industries Ltd.

          STOKES LAWRENCE, P.S. Matthew L. Harrington Mathew L. Harrington, WSBA #33276 Attorneys for Defendant Waldun Forest Products Ltd.

          AGREEMENT REGARDING DISCOVERY OF ELECTRONICALLY STORED INFORMATION AND ORDER

          THE HON. MARSHA J. PECHMAN, 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 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).

         C. Preservation of ESI

          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 ...


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