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DaVita Inc. v. Virginia Mason Memorial Hospital

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

June 17, 2019

DAVITA INC., Plaintiff,
v.
VIRGINIA MASON MEMORIAL HOSPITAL, f/k/a YAKIMA VALLEY MEMORIAL HOSPITAL and YAKIMA VALLEY MEMORIAL HOSPITAL EMPLOYEE HEALTH CARE PLAN Defendants.

          STRIS & MAHER LLP VIA EMAIL CONFIRMATION Michael Donofrio, Pro Hac Vice, KELLER ROHRBACK LLP VIA EMAIL CONFIRMATION Erin M. Riley, WSBA #30401 Attorneys for Plaintiff DaVita Inc.

          DAVIS WRIGHT TREMAINE LLP Richard Birmingham, WSBA #8685 Christine Hawkins, WSBA #44972 Attorneys for Defendants Virginia Mason Memorial Hospital, f/k/a Yakima Valley Memorial Hospital, and Yakima Valley Memorial Hospital Employee Health Care Plan

          AGREEMENT REGARDING DISCOVERY OF ELECTRONICALLY STORED INFORMATION AND ORDER

          Barbara Jacobs Rothstein U.S. District Court 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

         On or before the earlier of (1) 14 days after the Court's decision on the Defendants' motion to dismiss or (2) July 12, 2019, 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.

         Party-owned or controlled storage locations including servers, cloud-based servers, comprehensive mail storage systems, or web-accessible email services.

         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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