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Gohranson v. Snohomish County

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

May 24, 2017

JOHN T. GOHRANSON, individually, and as Personal Representative of the ESTATE OF LINDSAY M. KRONBERGER, Plaintiff,
v.
SNOHOMISH COUNTY, a Municipal Corporation in the State of Washington; ROBERT TRENARY; STUART ANDREWS, M.D.; DAN MILLER; ELAINE GRAVATT; GREGORY HARDY; SHERRISE HOLLAND; LAUREN KOOIMAN; JEAN LEIGHT; BETTY LUSK; JOY MAINE; LINET NGETE; ANDREW FLETCHER; RACHELLE ROSE; SHANE STEVIE; ROBIN OTTO; ROXANNE MARLER, AND JOHN AND JANE DOES 1-10; and MAXIM HEALTHCARE SERVICES, INC. d/b/a MAXIM STAFFING SOLUTIONS, a Maryland Corporation, and CASCADE HEALTHCARE SERVICES LLC, a Washington Limited Liability Corporation, Defendants.

          "Kenneth E. Brewe, WSBA, Karen D. Moore, WSBA, Brewe Layman P.S. Attorneys for Plaintiff

          W. Mitchell Cogdill, WSBA, Todd C. Nichols, WSBA, Mark P. Giuliano, WSBA, Colby Avenue, Suite 333 Cogdill Nichols Rein Wartelle Andrews Attorneys for Plaintiff

          Katherine Bosch, WSBA, Mikolaj T. Tempski, WSBA, Joseph G Genster, WSBA, Deputy Prosecuting Attorneys Attorneys for Defendant Snohomish County Snohomish County Prosecuting Attorney's

          [PROPOSED] STIPULATED PROTECTIVE ORDER

          Hon. Robert S. Lasnik, Judge

         STIPULATED PROTECTIVE ORDER

         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 produced or otherwise exchanged:
a. All Snohomish County Jail employee or personnel records; records of this nature may contain medical and/or psychological records, home addresses, personal telephone numbers, social security information, date of birth, or any other personal information.
b. Snohomish County Jail inmate records; records of this nature may contain medical and/or psychological records, social security information, date of birth, photographs, or any other private or confidential information. This includes, but is not limited to, healthcare records and Protected Health Information (PHI) related to inmates incarcerated in the Snohomish County Jail which is protected from disclosure pursuant to 45 CFR §164.12(e), RCW 70.02.060 and RCW 70.48.100.
c. The parties intend for this Order to comply with the requirements of RCW 70.48.100(c) that allows confidential inmate records to be made available "for use in court proceedings upon the written order of the court in which the proceedings are conducted." d. Ongoing investigation files; files of this nature may contain confidential medical records or may not yet be complete.
e. Autopsy/Cause of death information or reports.
f. All independent nursing agency employee or personnel records; records of this nature may contain medical and/or psychological records, home addresses, personal telephone numbers, social security information, date of birth, or any other personal information.
g. Any other information to be requested in discovery that has an equivalent need for protection from disclosure as this items identified in subparagraphs 2(a) through (f).

         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 identified and under the conditions described in this agreement. Confidential material must be stored and maintained by a receiving party at ...


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