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Etcheverry v. Franciscan Health System

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

June 26, 2019

HANA ETCHEVERRY, Individually and On Behalf of All Others Similarly Situated, Plaintiff,
v.
FRANCISCAN HEALTH SYSTEM D/B/A CHI FRANCISCAN HEALTH, FRANCISCAN MEDICAL GROUP, FRANCISCAN HEALTH VENTURES, HARRISON MEDICAL CENTER, and HARRISON MEDICAL CENTER FOUNDATION. Defendants.

          Jessica M. Andrade, WSBA #39297 POLSINELLI PC Donald L. Samuels (pro hac vice) POLSINELLI PC Attorneys for Defendants

          Beth E. Terrell, WSBA #2759 Toby J. Marshall, WSBA #32723 Erika L. Nusser, WSBA #40854 TERRELL MARSHALL LAW GROUP PLLC Carolyn H. Cottrell (pro hac vice) Ori Edelstein (pro hac vice) William M. Hogg (pro hac vice) SCHNEIDER WALLACE COTTRELL KONECKY WOTKYNS LLP Attorneys for Plaintiff

          THE HONORABLE ROBERT J. BRYAN, JUDGE

          AGREEMENT REGARDING DISCOVERY OF ELECTRONICALLY STORED INFORMATION AND [PROPOSED] ORDER

          Mary Alice Theiler United States Magistrate 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. If either party determines that the identification of additional custodians is necessary, the parties shall confer in good faith to address that issue and may so stipulate.

         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 ...


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