United States District Court, W.D. Washington, Seattle
PROVIDENCE HEALTH AND SERVICES; and SWEDISH HEALTH SERVICES, Plaintiffs,
CERTAIN UNDERWRITERS AT LLOYD'S LONDON, SYNDICATE 2623/623 BEAZLEY; and FEDERAL INSURANCE COMPANY, Defendants.
TILDEN THOMAS & CORDELL LLP, Franklin D. Cordell, Brendan
Winslow-Nason, Chelsey L. Mam, Attorneys for Plaintiffs
SMITH COCHRAN DICKERSON John M. Silk, Attorneys for
Defendants Certain Underwriters at Lloyd's London,
Syndicate 2623/623 (Beazley)
TROUTMAN SANDERS, Kevin F. Kieffer, Monique F. Fuentes, Ross
Smith, Attorneys for Defendants Certain Underwriters at
Lloyd's London, Syndicate 2623/623 (Beazley)
& LANG, PS Steven Soha, Geoffrey Bedell, Attorneys for
Defendant Federal Insurance Company
STIPULATED DISCOVERY PROTOCOL AND ORDER
RICARDO S. MARTINEZ, CHIEF UNITED STATES DISTRICT JUDGE
Providence Health and Services and Swedish Health Services
(collectively “Providence”) and Defendants
Certain Underwriters at Lloyd's London, Syndicate
2623/623 (Beazley) and Federal Insurance Company
(collectively “Insurers”) submit this Stipulated
Discovery Protocol, to supplement the parties Joint Status
Report and Discovery Plan.
attorney's zealous representation of a client is not
compromised by conducting discovery in a cooperative manner.
All parties agree to consult with each other in good faith on
any discovery issue to achieve resolution prior to raising
any issue with the Court.
proportionality standard set forth in Fed.R.Civ.P. 26(b)(1)
should 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 practicable.
party asserting undue hardship and/or unreasonable expense to
any request for production shall promptly meet and confer
regarding the review and production of the requested
Standard for Disclosures:
party shall disclose:
Custodians. The custodians most likely to have discoverable
ESI data and hard copy documents 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.
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, indicate the extent
to which a party is ...