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Mao v. U.S. Bank National Association

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

March 22, 2017

RUI MAO, QINGBIN BU, RUI FAN, ZHEN FAN, BING HUANG, WENLAN HUANG, SHUANGYAN JIA, TIEYIN LI, HUAIJIN LIU, ZHONGFA LIU, XINYUAN MU, ZHICUI SHAN, YAO SONG, HAILAN TANG, PEILIN WU, HAITAO XU, XIUQIN YANG, ZHAOHUI YE, JUNHONG ZHANG, ZHONGMEI ZHAO, DIANYI ZHOU, JIAYIN ZHU, XIAOYU ZHU, LIXIN CHEN, WEIYI DAI, ZHE FENG, JIUYI GENG, YUE GU, MIN GUO, QING HUANG, HESHENG LEI, CHUNFENG LI, DANLI LI, XINKAI LI, RUIPING TAO, MANSHAN TONG, MING-JEN TSAI, YIPENG WU, ZHIJUN WU, CHEN XUAN, XIAOSHU YANG, and XIAOLIN YIN, Plaintiffs,
v.
U.S. BANK NATIONAL ASSOCIATION; QUARTZBURG GOLD, LP; ISR CAPITAL, LLC; IDAHO STATE REGIONAL CENTER, LLC; and SIMA MUROFF, Defendants.

          Michael Black, admitted pro hac vice Parr Brown Gee & Loveless and Lawrence Carl Locker, Steven O Fortney, Attorneys for Plaintiffs Except Bin Xu

          Peter Ehrlichman, Shawn Larsen-Bright, Andrea Yang, Dorsey & Whitney LLP, Attorneys for Defendant U.S. Bank National Association

          Matthew Sava, admitted pro hac vice Reid & Wise LLC and Benjamin I. VandenBerghe, Montgomery Purdue Blankinship & Austin, Attorneys for Plaintiff Bin Xu

          Eric B. Swartz, admitted pro hac vice Jones & Swartz PLLC and Thomas M. Brennan, Krysta A. Liveris, McKay Chadwell, PLLC, Attorneys for Defendants Quartzburg Gold, LP, ISR Capital, LLC, Idaho State Regional Center, LLC, and Sima Muroff

          STIPULATED PROTECTIVE ORDER

          RICARDO S. MARTINEZ, CHIEF UNITED STATES DISTRICT JUDGE

         Pursuant to Federal Rule of Civil Procedure 26(c) and Local Civil Rule 26(c)(2), the parties hereto hereby stipulate and agree to, and respectfully move this Court to enter, the below Protective Order.

         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 the limited information or items that are entitled to confidential treatment under the 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: non-public bank statements and other records of banking or financial transactions; accounting records; tax returns and tax information returns; financial statements; personnel and/or employment records; insurance records; internal policies, procedures, and forms; business plans, projections, or strategies; customer information; information regarding particular financial accounts; passports; documents containing personally identifying information; documents containing individual addresses and phone numbers; documents containing names of children; documents containing individual financial account numbers; documents containing any other information subject to protection under HIPAA or other privacy laws; and sensitive information akin to the documents specified herein produced by a non-party.

         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 this 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 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 ...

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