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Connolly v. Umpqua Bank

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

April 6, 2017

SARAH CONNOLLY, individually and on behalf of all others similarly situated, Plaintiff,
v.
UMPQUA BANK, and STERLING INFOSYSTEMS, INC., Defendants.

          Davis Wright Tremaine LLP Attorneys for Defendant Umpqua Bank James E. Howard, WSBA #37259 Samantha Funk, WSBA #43341

          Bailey & Glasser LLP Attorneys for Plaintiff Elizabeth Ryan (admitted pro hac vice) Michael L. Murphy, WSBA #37481 BAILEY & GLASSER LLP And Beth E. Terrell, WSBA #26759 TERRELL MARSHALL LAW GROUP And Nicholas F. Ortiz LAW OFFICE OF NICHOLAS F. ORTIZ, P.C

          STIPULATED PROTECTIVE ORDER

          The Honorable Thomas S. Zilly 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 Local Rules W.D. Wash. 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) documents that contain financial or personal identifying information, such as e-mail addresses, physical addresses, telephone numbers, and account numbers;

         (b) documents that contain information regarding Umpqua's employees, customers, or clients.

         (c) documents concerning Umpqua's proprietary training, marketing, guidelines, policies, procedures, software, databases, or business practices;

         (d) documents concerning Umpqua's efforts to ensure its compliance with federal and state laws and regulations regarding obtaining consumer reports, including credit reports, background checks, and criminal history reports;

         (e) documents concerning Umpqua's review and assessment of consumer reports obtained as part of its application process;

         (f) Umpqua's contracts with consumer reporting agencies; and

         (g) any other documents that contain confidential business information of either party as determined and designated by such party.

         The parties may propose modifying this list if necessary as discovery proceeds.

         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 ...


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