United States District Court, W.D. Washington, Seattle
ESTATE OF NICKOLAS MICHAEL PETERS, by the Personal Representative CARL MICHAEL PETERS; and JAYNI MARIE PETERS and CARL MICHAEL PETERS, individually and their marital community, Plaintiffs,
SNOHOMISH COUNTY as a subdivision of the STATE of WASHINGTON; SNOHOMISH COUNTY DEPUTY SHERIFF ARTHUR J. WALLIN; and CERTAIN UNKNOWN SNOHOMISH COUNTY DEPUTY SHERIFFS JOHN & JANE DOES 1 - 3, Defendants.
G. Arnold, Campiche Arnold, PLLC Attorneys for Plaintiffs
Bridget E. Casey, Joseph B. Genster, Katherine H. Bosch,
Attorneys for Def. Snohomish County
Shannon M. Ragonesi Keating Bucklin & McCormack, Inc., PS
Attorneys for Defendant Deputy Wallin
STIPULATION FOR DISCOVERY OF ELECTRONICALLY STORED
INFORMATION (ESI) AND ORDER
S. Zilly United States District Judge
parties hereby stipulate to the following provisions
regarding the discovery of electronically stored information
(ESI) in this matter:
attorney's zealous representation of a client is not
compromised by conducting discovery in a cooperative manner.
The failure of counsel or the parties in litigation to
cooperate in facilitating and reasonably limiting discovery
requests and responses raises litigation costs and
contributes to the risk of sanctions.
proportionality standard set forth in Fed.R.Civ.P. 26(b) (2)
(B) 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.
30 days after the Rule 26(f) conference, or at a later time
if agreed to by the parties, each party shall disclose:
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
Non-custodial Data Sources. A list of non-custodial data
sources (e.g., shared drives, servers, data bases,
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, the extent to which
a party is (or is not) able to preserve information stored in
the third-party data source.
Manual Data. Drawings, illustrations, photographs, images,
documents and ESI of a party which are not subject to
effective computer word searches are still subject to the
discovery requests from the ...