Rhea v. Washington Dep?t of Corr., 2010 WL 5395009 (W.D. Wash. Dec. 27, 2010)

Key Insight: Court found that defendant had failed to ask all employees with potentially relevant documents to search for and produce them, that some employees who were asked to search had not complied, and that employees who had complied failed to search for documents in all possible locations and granted plaintiff?s motion to compel additional searching and production; court granted motion to compel defendants to provide a complete answer to an interrogatory seeking detailed information on steps taken to locate responsive materials and ordered defendant to ?certify that all employees with potentially responsive documents searched all locations where such documents are typically stored in paper or electronic format?

Nature of Case: Claims that defendant refused to provide necessary medical care or accommodate plaintiff’s disability

Electronic Data Involved: ESI, emails