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BGH Holdings, LLC v. DL Evans Bank

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

October 30, 2019

BGH HOLDINGS, LLC, a Washington limited liability company; GINGER ATHERTON; HENRY DEAN, and their marital community, Plaintiff,
v.
DL EVANS BANK, Defendant,
v.
FRANK DEAN, JIM DEAN and WN3, LLC, Additional Parties.

          WESTERN WASHINGTON LAW GROUP, PLLC Attorneys for Plaintiffs and Additional Parties Robert J. Cadranell, II, WSBA #41773

          DAVIS WRIGHT TREMAINE, LLP Attorneys for Defendant DL Evans Bank Rhys M. Farren, WSBA #19398

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

          HONORABLE ROBERT S. LASNIK 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 be reasonably targeted, clear, and as specific as possible.

         B. ESI Disclosures

         Within 30 days after entry of this Order, each party shall disclose:

         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 asserts is not reasonably accessible under Fed. R. Civ. I P. 26(b)(2)(B). Section (C)(3)(a)-(h) below sets forth data sources and ESI which are not required to be preserved by the parties. Those data sources and ESI do not need to be included on this list.

         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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