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White v. Spokane County

United States District Court, E.D. Washington

May 5, 2017

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

          GILBERT LAW FIRM, P.S., WILLIAM A. GILBERT, Attorneys for Plaintiffs.

          EVANS, CRAVEN &LACKIE, P.S., HEATHER C. YAKELY, Attorney for Defendants.

          STIPULATED PROTECTIVE ORDER REGARDING PLAINTIFFS' MEDICAL RECORDS

          THOMAS O. RICE Chief United States District Judge.

         I. STIPULATION

         Pursuant to FRCP 26(c), the parties through their respective counsel agree and stipulate that good cause exists to protect BARRY L. WHITE, and LORRAINE M. WHITE (“Plaintiffs”), and SPOKANE COUNTY; AND, SPOKANE COUNTY SHERIFF'S DEPUTIES MARK HOLTHAUS, BRAD GILBERT and TODD MILLER (“defendants”), and non-parties from annoyance, undue burden and expense from the public disclosure of Plaintiffs' medical information.

         1. This Stipulated Protective Order (“Protective Order”) shall govern the treatment and handling of all medical records, documents or other products of discovery produced by Plaintiff and Defendants or information derived therefrom, and all copies, excerpts or summaries thereof including (without limitation), answers to requests for admissions, answers to interrogatories, documents produced pursuant to a demand for documents, documents subpoenaed in connection with depositions, and deposition transcripts, that a party designates as “confidential” by marking clearly on the document: “CONFIDENTIAL SUBJECT TO PROTECTION ORDER”

         2. All medical records, and related documents, and images obtained by way of release, or disclosed by plaintiff and defendants are presumed by this order to be confidential and governed hereby.

         3. Testimony taken in deposition in this case similarly may be designated as confidential and made subject to the terms of this order at the time of the deposition by designation made by counsel on the record.

         4. Any party may move the court to determine the propriety of confidentiality. Information, documents or data subject to the challenge shall remain confidential until such time as the matter is determined by the court.

         5. Documents, photographs, videotapes, materials, or information designated confidential pursuant to this order shall not be disclosed or disseminated outside of the offices of plaintiffs' and defendants' counsel, with the following exceptions.

a. Use of such confidential documents, or information for trial preparation by paralegal or secretarial staff of plaintiffs' and defendants' attorneys is allowed by this Protective Order, subject to all conditions of this Protective Order which governs the parties' use of such confidential information;
b. Plaintiffs' medical records designated by the parties as confidential may be provided to expert witnesses, or consultants by plaintiffs' or defendants' attorneys provided such expert witnesses or consultants, before being allowed to see any confidential documents, materials, or information, acknowledge receipt of a copy of this Protective Order and agree to be bound by the terms of this Protective Order. The prohibition of this paragraph shall apply in all circumstances, including, but not limited to, depositions in this case.

         6. All persons having access to Plaintiffs' medical records made available pursuant to this agreement shall agree not to make any use of said records except in connection with the above-captioned litigation and shall further agree not to deliver or transfer said medical records to any person not previously authorized by the terms herein.

         7. Counsel disclosing medical records to any person or entity shall be responsible for limiting distribution of the records to those persons who both (1) have a need to know the information, and (2) are authorized to receive the information under this Protective Order. Counsel shall be ...


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