United States District Court, W.D. Washington, Seattle
ROBERT JOHNSON and KRISTIN JOHNSON, husband and wife, Plaintiffs,
NATIONSTAR MORTGAGE LLC, a Delaware limited liability company, Defendant.
LLP Barbara L. Bollero, Attorneys for Defendant Nationstar
Sturdevant, Attorney for Plaintiffs.
STIPULATION OF PARTIES RE CONFIDENTIAL PROTECTED
MATERIALS AND [PROPOSED] ORDER
L. ROBART U.S. District Court Judge.
PURPOSES AND LIMITATIONS
in this action is likely to involve production of
confidential, proprietary, private, and/or confidential
information for which special protection is warranted,
Accordingly, Plaintiffs Robert Johnson and Kristin Johnson,
and Defendant Nationstar Mortgage LLC
("Nationstar"), hereby stipulate to and petition
the Court to enter the following Stipulated Protective Order.
parties acknowledge that this Stipulation 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 applicable legal principles, and
it does not presumptively entitle parties to file
confidential information under seal.
material shall include the following documents and tangible
things produced or otherwise exchanged:
Any person's confidential personal financial information,
including bank account numbers, former or current loan
numbers, social security numbers, and related personal
identifying and/or financial information included on loan
applications, bank statements, mortgage, statements, tax
returns, property preservation records, and/or related
Nationstar's documented communications with third-parties
and entries contained within Nationstar's Collection
History Profile and LPS Notes referencing property inspection
and preservation services concerning, and the Notice of
Default to be served on, Richard E. McKinley and Louann C.
McKinley (the "McKinley's") for their loan
serviced by Nationstar and secured by the real property
formerly owned by the McKinley's at Lot 5, Sudden Valley,
Division No. 38, Whatcom County, Washington (the
All other materials as may be designated by the parties and
included by way of Amended Stipulations re Confidential
Protected Materials, to be filed with the Court.
protections conferred by this Stipulation cover not only
confidential materials (as defined above), but also: (1) any
information copied or extracted from confidential materials;
(2) all copies, excerpts, summaries, and/or compilations of
confidential materials; and (3) any testimony, conversations,
and/or presentations by parties and/or their counsels that
might reveal confidential materials. However, the protections
conferred by this Stipulation do not cover information that
is in the public domain or becomes part of the public domain
through trial or otherwise.
ACCESS TO AND USE OF CONFIDENTIAL MATERIAL
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, and/or attempting to settle
this litigation. Confidential material may be disclosed only
to the categories of persons and under the conditions
described in this Stipulation. 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 Stipulation.
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
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 ...