John A. McGuinn, Esq., (State Bar No. 036047), Jeannette A. Vaccaro, Esq., (State Bar No. 287129), McGUINN, HILLSMAN & PALEFSKY, San Francisco, CA, Attorneys for Plaintiff JOE CONNELLY.
LITTLER MENDELSON, P.C., JOSEPH A. SCHWACHTER, Attorneys for Defendant HANJIN SHIPPING AMERICA, LLC.
STIPULATED ORDER RE: DISCOVERY OF ELECTRONICALLY STORED INFORMATION FOR STANDARD LITIGATION
RICHARD SEEBORG, Magistrate Judge.
This Order will govern discovery of electronically stored information ("ESI") in this case as a supplement to the Federal Rules of Civil Procedure, this Court's Guidelines for the Discovery of Electronically Stored Information, and any other applicable orders and rules.
The parties are aware of the importance the Court places on cooperation and commit to cooperate in good faith throughout the matter consistent with this Court's Guidelines for the Discovery of ESI.
The parties have identified liaisons to each other who are and will be knowledgeable about and responsible for discussing their respective ESI. Each e-discovery liaison will be, or have access to those who are, knowledgeable about the technical aspects of e-discovery, including the location, nature, accessibility, format, collection, search methodologies, and production of ESI in this matter. The parties will rely on the liaisons, as needed, to confer about ESI and to help resolve disputes without court intervention.
The parties have discussed their preservation obligations and needs and agree that preservation of potentially relevant ESI will be reasonable and proportionate. To reduce the costs and burdens of preservation and to ensure proper ESI is preserved, the parties agree that:
a) Only ESI created or received between August 1, 2007 and December 31, 2012, will be preserved;
b) The parties have exchanged a list of the types of ESI they believe should be preserved and the custodians, or general job titles or descriptions of custodians, for whom they believe ESI should be preserved, e.g., "HR head, " "scientist, " and "marketing manager." ...