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Titan Global LLC, A Nevada Limited v. Organo Gold Int'l

January 9, 2013

TITAN GLOBAL LLC, A NEVADA LIMITED
LIABILITY COMPANY; MATHEW RASMUSSEN AND LISA RASMUSSEN, HUSBAND AND WIFE, RESIDENTS OF CALIFORNIA,
PLAINTIFFS,
v.
ORGANO GOLD INT'L, INC., A WASHINGTON CORPORATION; HOLTON BUGGS JR. AND JANE DOE BUGGS, TEXAS RESIDENTS; ROMACIO FULCHER, A SINGLE MAN AND A CALIFORNIA RESIDENT;
RRAMON FULCHER SR. AND TYRA FULCHER, HUSBAND AND WIFE, CALIFORNIA
RESIDENTS; KYLE A. SOLON, A SINGLE MAN AND A CALIFORNIA RESIDENT; JOHN DOES AND JANE
DOES 1-25; JOHN DOES AND JANE DOES 26-50; XYZ CORPORATIONS AND LLC'S 1-25; AND XYZ CORPORATIONS AND LLCS 1-25,
DEFENDANTS.



The opinion of the court was delivered by: Honorable Lucy H. Koh

Brook B. Bond, SBN 144815 PARSONS BEHLE & LATIMER 2 960 Broadway Avenue, Suite 250 Boise, Idaho 83706 3 Telephone: (208) 562-4900 Facsimile: (208) 562-4901 4 Email: bbond@parsonsbehle.com 5 Attorneys for Defendant OrGano Gold Int'l, Inc. 6 7

STIPULATED ORDER RE: DISCOVERY OF ELECTRONICALLY STORED INFORMATION

COME NOW the parties, by and through their respective undersigned counsel of record, in 22 compliance with the Local Rules of this Court, and hereby agree to the entry of the following Stipulated 23

Order Re: Discovery of Electronically Stored Information. 24

1. PURPOSE

This Order will govern discovery of electronically stored information ("ESI") in this case as a 3 supplement to the Federal Rules of Civil Procedure, this Court's Guidelines for the Discovery of 4 Electronically Stored Information, and any other applicable orders and rules. 5

2. COOPERATION

The parties are aware of the importance the Court places on cooperation and commit to cooperate in 7 good faith throughout the matter consistent with this Court's Guidelines for the Discovery of ESI. 8

3. LIAISON

The parties have identified liaisons to each other who are and will be knowledgeable about and 10 responsible for discussing their respective ESI. Each e-discovery liaison will be, or have access to those 11 who are, knowledgeable about the technical aspects of e-discovery, including the location, nature, 12 accessibility, format, collection, search methodologies, and production of ESI in this matter. The parties 13 will rely on the liaisons, as needed, to confer about ESI and to help resolve disputes without court 14 intervention. 15

4. PRESERVATION

The parties have discussed their preservation obligations and needs and agree that preservation of 17 potentially relevant ESI will be reasonable and proportionate. To reduce the costs and burdens of 18 preservation and to ensure proper ESI is preserved, the parties agree that: 19

a) Only ESI created or received between January 1, 2008 and Final Disposition of this matter, as 20 defined in the Stipulated Protective Order entered in this case, will be preserved; 21

b) The parties have agreed/will agree on the number of custodians per party for whom ESI ...


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