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PTP OneClick, LLC v. Avalara, Inc.

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

August 21, 2019

PTP ONECLICK, LLC, Plaintiff,
v.
AVALARA, INC., Defendant.

          Collin Kartenbach, Shane P. Cramer, WSBA No. 35099, Tyler L. Farmer, WSBA No. 39912 Harrigan Leyh Farmer & Thomsen LLP William E. Devitt (pro hac vice), Timothy J. Heverin (pro hac vice), Collin Kurtenbach (pro hac vice) Jones Day Attorneys for Plaintiff PTP OneClickLLC

          Charles C. Sipos, WSBA No. 32825, Ryan J. McBrayer, WSBA No. 28338 Perkins Coie LLP Attorneys for Defendant Avalara, Inc.

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

          THE HONORABLE JAMES L. ROBART, UNITED STATES DISTRICT 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 he reasonably targeted, clear, and as specific as possible.

         B. ESI Disclosures

         The parties shall, on or before August 28, 2019, disclose the following:

         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 ...


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