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Green v. Swedish Health Services

United States District Court, W.D. Washington

March 30, 2017

JOEL GREEN, an individual, Plaintiff,
v.
SWEDISH HEALTH SERVICES, a Washington Non-Pro fit Corporation, Defendant.

          Aaron V. Rocke, WSBA No. 31525 Rocke Law Group, PLLC Attorneys for Plaintiff Joel Green

          Ryan P. Hammond, WSBA No. 38888 Vanessa B. Lee, WSBA No. 46547 Attorneys for Defendant Swedish Health Services

          STIPULATION FOR PROTECTIVE ORDER

          JOHN C. COUGHENOUR 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 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 producec or otherwise exchanged:

         (a): Protected health care information for current or former employees of Swedish Health Services;

         (b): Social Security Numbers and dates of birth for current or former employees of Swedish Health Services;

         (c): Financial information for current or former employees of Swedish Health Services;

         (d): Personnel files of non-parties.

         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 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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