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In re Impinj, Inc.

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

December 17, 2019

IN RE IMPINJ, INC., SECURITIES LITIGATION

          Barry M. Kaplan Gregory L. Watts John C. Roberts Jr., Christopher M.E. Petroni, Wilson Sonsini Goodrich & Rosati, P.C. Counsel for Defendants Impinj, Inc., Chris Diorio, Evan Fein, and Eric Brodersen

          Bradley S. Keller Byrnes Keller Cromwell LLP Liaison Counsel for Lead Plaintiff Employees' Retirement System of the City of Baton Rouge and Parish of East Baton Rouge

          Jonathan D. Uslaner (pro hac vice) Lauren M. Cruz (pro hac vice) Bernstein Litowitz Berger & Grossmann LLP Salvatore Graziano (pro hac vice) Michael D. Blatchley (pro hac vice) Bernstein Litowitz Berger & Grossmann LLP Counsel for Lead Plaintiff Employees' Retirement System of the City of Baton Rouge and Parish of East Baton Rouge

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

          THE HONORABLE ROBERT S. LASNIK UNITED STATES DISTRICT COURT 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 Rule 26(b)(1) of the Federal Rules of Civil Procedure 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

         Each party shall promptly disclose to the other party:

         1. Custodians. The 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 Rule 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 respect to preservation of ESI, the parties agree as follows:

         1. Absent a showing of good cause by the requesting party, the parties shall not be required to modify the procedures used by them in the ordinary course of business to back-up and archive data; provided, however, that the parties shall ...


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