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Bund v. Safeguard Properties, LLC

United States District Court, W.D. Washington

March 22, 2017

JOHN R. BUND II, personally, as Executor of the Estate of Richard C. Bund, deceased; MANDY HANOUSEK and GARETT HANOUSEK, a married couple, and on behalf of others similarly situated, Plaintiff,
v.
SAFEGUARD PROPERTIES, LLC, a Delaware corporation, Defendant,

          JEFFERS, DANIELSON, SONN & AYLWARD, P.S. SALLY F. WHITE. CLAY M. GATENS, WSBA No. 34102 SALLY F. WHITE, WSBA No. 49457 Attorneys for Plaintiffs

          LEE SMART, P.S., INC, Pamela J. DeVet Marc Rosenberg, WSBA No. 31034 Pamela J. DeVet, WSBA No. 32882 Lee Smart, P.S., Inc. Attorneys for Defendant Safeguard Properties Management, LLC

          STIPULATED PROTECTIVE ORDER

          James L. Robart, 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 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: (a) Defendant's (i) policies and procedures, (ii) client list, (iii) master services agreements with clients, (iv) agreements with -vendors, (v) personnel tiles; (vi) proprietary software; (vii) company financials; (b) information regarding borrowers' loan histories, (c) dates of birth and social security and driver's license numbers of the named Plaintiffs and putative class members.

         Further, Defendant's list of its clients which have engaged Defendant during the class period identified by Plaintiffs for services related to properties in the State of Washington will be marked "Confidential - Attorney's Eyes Only" and will be disclosed only between and among counsel for the parties. Counsel for plaintiffs shall not create any electronic copies. In court filings and discussions with class members, counsel for Plaintiffs will be permitted to refer to the fact of the list, how many names are on it that the properties are located in the state of Washington, and similar information that does not disclose the complete contents of the list.

         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 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 Counsel shall not disclose to any person a document marked "CONFIDENTIAL -ATTORNEYS' EYES ONLY, " Counsel may disclose information about such document only as described in ¶ 2.

         4.3 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 ...

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