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White v. Spokane County

United States District Court, E.D. Washington

April 5, 2017

BARRY L. WHITE and LORRAINE M. WHITE, husband and wife, Plaintiffs,
v.
SPOKANE COUNTY, and MARK HOLTAUS; and BRAD GILBERT; and TODD MILLER; Individually and in their capacity as employees of Spokane County. Defendants.

          EVANS, CRAVEN & LACKIE, P.S. BY HEATHER C. YAKELY, ATTORNEY FOR DEFENDANTS

          LAW OFFICE WILLIAM A. GILBERT BY WILLIAM A. GILBERT, ATTORNEY FOR PLAINTIFFS

          STIPULATED PROTECTIVE ORDER

          HONORABLE JUDGE THOMAS O. RICE JUDGE

         ORDER

         IT IS HEREBY ORDERED that the following procedures shall apply to the personnel, internal affairs, training records, hiring files, employment files, FTO files, administrative files and any other files pertaining to deputies of Spokane County Sheriff's Department, and any documents, written or other that contain any personal information regarding any third party in the above-referenced matter or not a party hereto but pursuant to a request for release by Plaintiff's counsel. Spokane County has designated these records as confidential subject to the following provisions:

         1. The personnel records, employment records, hiring files, administrative files, training records, and/or internal affairs reports and/or investigations, financial and tax records, of all deputies of the Spokane County Sheriff's Department (herein “Records”), and shall be produced and used solely for the purposes of this litigation and shall not be disclosed, except pursuant to court order, to anyone except:

a. The party(ies), their attorneys and the attorney's employees;
b. Consultants and experts retained by any party for the purposes of assisting in the preparation or presentation of claims or defenses;
c. Any other person with prior written consent of the party producing the documents.

         2. All of the foregoing persons, other than the parties' attorneys and their employees, shall be shown a copy of this order and shall sign it or otherwise signify in writing prior to being shown confidential documents that the person has read the order and consents to be bound by its terms. Attached hereto as Exhibit A is a sample copy of a consent form.

         3. All documents bearing the social security, dates of birth, bank account identifications, financial information, and driver's license of any individual, whether a sheriff deputy or a third party, shall be redacted prior to providing a copy of the same to Plaintiff's counsel.

         4. All documents bearing the addresses and phone numbers of Sheriff Deputies or other law enforcement personnel and those individual's friends and families shall be redacted prior to providing a copy of the same to Plaintiff's counsel.

         5. The addresses and phone numbers of non-party individuals mentioned, referenced, or noted in any way in the above-referenced documents (Paragraph 1) shall also be redacted.

         6. Prior to the filing or submission into evidence in this action of any “Confidential” material (including the filing of any pleadings which incorporate or disclose “Confidential” material) by counsel for either party in this action, said counsel shall seal said and is to be retained under seal unless ordered by the Court to be opened. Such sealing and filing shall be accomplished in accordance with the appropriate court rules for filing material under seal, and the material shall remain under seal with the Court order otherwise. Such “Confidential” material shall not become a part of the public record in this action, nor shall it otherwise be made available to the public. Only persons authorized under the provisions of this Protective Order, the Court (including any court to which this action may be ...


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