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Providence Health & Services v. Certain Underwriters at Lloyd's London

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

July 25, 2019

PROVIDENCE HEALTH AND SERVICES; and SWEDISH HEALTH SERVICES, Plaintiffs,
v.
CERTAIN UNDERWRITERS AT LLOYD'S LONDON, SYNDICATE 2623/623 BEAZLEY; and FEDERAL INSURANCE COMPANY, Defendants.

          GORDON TILDEN THOMAS & CORDELL LLP, Franklin D. Cordell, Brendan Winslow-Nason, Chelsey L. Mam, Attorneys for Plaintiffs

          WILSON 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)

          SOHA & 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

         Plaintiffs 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.

         A. General Principles:

         1. An 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.

         2. The 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.

         3. Any 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 data/documents.

         B. Standard for Disclosures:

         Each party shall disclose:

         1. 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.

         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, indicate the extent to which a party is ...


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