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Hancock v. Aetna Life Insurance Co.

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

September 15, 2017

JUDITH HANCOCK, Plaintiff,
v.
AETNA LIFE INSURANCE COMPANY; THE BOEING COMPANY EMPLOYEE HEALTH AND WELFARE BENEFIT PLAN PLAN 503; and EMPLOYEE BENEFIT PLANS COMMITTEE, Defendants,

          GORDON & REES SCULLY MANSUKHANI Sarah Turner, WSBA #37748 Brittany Stevens, WSBA Attorneys for Defendants

          LAW OFFICE OF MEL CRAWFORD, Mel Crawford, WSBA Attorney for Plaintiff

          AGREED MOTION AND [PROPOSED] ORDER REGARDING USE OF MODEL STIPULATED PROTECTIVE ORDER

          Hon. James L, Robart United St ites District Judge

         I. AGREED MOTION

         The parties, through their undersigned counsel of record, jointly move this Court to enter the Protective Order attached as Dkt. No. 66-1. The Protective Order is based on the Western District of Washington's Model Stipulated Protective Order. It has been signed by counsel for both parties, and concerns documents produced by Defendants in response to discovery requests from Plaintiff Judith Hancock, Specifically, Defendants are required to produce documents related to policies in place at the time Plaintiffs long-term disability claim and appeal were pending, which Defendants allege are confidential and proprietary documents. See Dkt. No. 63, 18:8-11. .

         II. AGREED MOTION

         Pursuant to the parties' agreed motion, it is so ORDERED. Defendants may file the Stipulated Protective Order as that document appears at Dkt. No. 66-1.

         DECLARATION OF SERVICE

         The undersigned, declares under penalty of perjury under the laws of the State of Washington that on this day, I electronically filed a true and accurate copy of the document to which this declaration is affixed with the Clerk of the Court using the CM/ECF System, which will electronically mail notice to:

Mel Crawford Law Office of Mel Crawford 9425 35th Ave. NE, Suite C Seattle, WA 98155 Email: melcrawford@melcrawfordlaw. com

         MODLE STIPULATED PROTECTIVE ORDER

         HON. JAMES L. ROBART

         1. PURPOSES AND LFMITATIONS

         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:

         Documents produced by Defendants Bates-stamped AET003687-4134.

         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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