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Albert v. Laboratory Corporation of America

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

September 25, 2019

ROBERT ALBERT, an individual, Plaintiff,
v.
LABORATORY CORPORATION OF AMERICA, a Delaware Corporation Defendant.

          HKM EMPLOYMENT ATTORNEYS LLP Jason A. Rittereiser, WSBA No. 43628 Donald W. Heyrich, WSBA No. 23091 Daniel Kalish, WSBA No. 35815 Rachel M. Emens, WSBA No. 49047 Henry Brudney, WSBA No. 52602 Attorneys for Plaintiff Robert Albert

          SEBRIS BUSTO JAMES Jeffery A. James, WSBA #18277 Attorneys for Defendant LabCorp

          KELLEY DRYE & WARREN LLP Robert I. Steiner, Pro Hac Vice Steven R. Nevolis, Pro Hac Vice Attorneys for Defendant LabCorp

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

          MICHELLE L. PETERSON 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 20 days after the date the parties sign this Agreement, each party shall disclose:

1. Custodians. The seven 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, social media websites, 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 asserts is not reasonably accessible under Fed.R.Civ.P. 26(b)(2)(B).

         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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