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Poore-Rando v. United States

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

June 7, 2017

SAMANTHA POORE-RANDO and MATTHEW RANDO, husband and wife, Plaintiffs,
v.
UNITED STATES OF AMERICA, et al., Defendants.

          Priscilla T. Chan, Whitney Passmore, Assistant United States Attorney Attorneys for Defendant

          HAROLD KARLSVIK, P.S. Attorneys for Plaintiff

          BETTS, PATTERSON & MINES, P.S. Christopher W. Tompkins Attorney for Defendants Johnson & Johnson; Ethicon Endo-Surgery, Inc.

          AMENDED STIPULATED PROTECTIVE ORDER

          BENJAMIN H. SETTLE United States District Judge

         1. PURPOSES AND LIMITATIONS

         The Parties previously stipulated to, and the Court previously entered, a Protective Order in this matter. ECF No. 36, 37. That Order addressed Plaintiff's medical records and related materials. The Parties wish to amend that Order to include additional discovery materials to be produced by Defendant Ethicon Endo-Surgery, Inc., as set forth in § 2. In addition, the Parties wish to enter a non-waiver order under Fed.R.Evid. 502(d), as suggested in the revised Model Protective Order promulgated for the Western District.

         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: Plaintiff's medical records and any statements or reports that discuss Plaintiff's medical care.

         In addition, “Confidential” material shall include documents reflecting or related to:

(1) product design and drawings;
(2) product manufacturing and quality control/quality assurance;
(3) Product Inquiry Investigation files;
(4) trade secrets or other proprietary research, development or commercial information including but not limited to business plans or financial information;
(5) private individual personal health or financial information; and
(6) documents prepared for regulatory agencies, including confidential communications with the FDA. The names and addresses of patients and physicians shall be redacted, as well as all identifying information regarding the reporters in such a manner as not to redact material data contained in such reports and consistent with the requirements of 21 C.F.R. 20.63(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 Basi ...


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