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Tokarski v. Navient Solutions, Inc.

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

February 2, 2017

KIMBERLY TOKARSKI, Plaintiff,
v.
NAVIENT SOLUTIONS, INC., Defendant.

          Richard J. Symmes Symmes Law Group, PLLC Attorney for Plaintiff Kimberly Tokarski

          Carolyn A. Pearson Jordan Ramis PC Attorney for Defendant Navient Solutions, Inc.

          STIPULATED PROTECTIVE ORDER

          Robert S. Lasnik United States District Judge

         1. PURPOSES AND LIMITATIONS

         Discovery in this action is likely to involve production of confidential, proprietary, or private information for which special protection may be warranted. Accordingly, the parties hereby stipulate to and petition the court to enter the following Stipulated Protective Order. The parties acknowledge that this agreement is consistent with LCR 26(c). It does not confer blanket protection on all disclosures or responses to discovery, the protection it affords from public disclosure and use extends only to die limited information or items that are entitled to confidential treatment under die applicable legal principles, and it does not presumptively entitle parties to file confidential information under seal.

         2. "CONFIDENTIAL" MATERIAL

         "Confidential" material shall include the following documents and tangible things produced or otherwise exchanged: [The parties must include a list of specific documents such as "company's customer list" or "plaintiffs medical records;" do not list broad categories of documents such as "sensitive business material”]. Defendant. Navient Solutions, Inc. (NSI)'s call logs; NSI's servicing notes and other internal business records related to Plaintiff Kimberly Tokarski's student loans; documents relating to NSI's dialing system; documents relating to proprietary business methods and practices; documents containing personal information, including personal financial information about customers or applicants, any party to this lawsuit, or an employee of any party to this lawsuit; documents regarding any individual's banking or lending relationship, including, without limitation, information regarding any individual's mortgage or credit history and/or consumer information not otherwise available to the public.

         3. SCOPE

         The protections conferred by this agreement cover not only confidential material (as defined above), but also (1) any information copied or extracted from confidential material; (2) all copies, excerpts, summaries, or compilations of confidential material; and (3) any testimony, conversations, or presentations by parties or their counsel that might reveal confidential material. However, the protections conferred by mis agreement do not cover information that is in the public domain or becomes part of the public domain through trial or otherwise.

         4. ACCESS TO AND USE OF CONFIDENTIAL MATERIAL

         4.1 Basic Principles. A receiving party may use confidential material that is disclosed or produced by another party or by a non-party in connection with this case only for prosecuting, defending, or attempting to settle this litigation. Confidential material may be disclosed only to the categories of persons and under the conditions described in this agreement. Confidential material must be stored and maintained by a receiving party at a location and in a secure manner that ensures that access is limited to the persons authorized under this agreement.

         4.2 Disclosure of "CONFIDENTIAL" Information or Items. Unless otherwise ordered by the court or permitted in writing by the designating party, a receiving party may disclose any confidential material only to:

(a) the receiving party's counsel of record in this action, as well as employees of counsel to whom it is reasonably necessary to disclose the information for this litigation;
(b) the officers, directors, and employees (including in house counsel) of the receiving party to whom disclosure is reasonably necessary for this litigation, unless the parties agree that a particular document or material produced is for Attorney's Eyes Only and is so designated;
(c) experts and consultants to whom disclosure is reasonably necessary for this litigation and who have signed the "Acknowledgment and Agreement to ...

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