United States District Court, W.D. Washington, Seattle
& REES SCULLY MANSUKHANI Sarah Turner, WSBA #37748
Brittany Stevens, WSBA Attorneys for Defendants
OFFICE OF MEL CRAWFORD, Mel Crawford, WSBA Attorney for
AGREED MOTION AND [PROPOSED]
ORDER REGARDING USE OF MODEL STIPULATED PROTECTIVE
James L, Robart United St ites District Judge
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. .
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.
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:
STIPULATED PROTECTIVE ORDER
JAMES L. ROBART
PURPOSES AND LFMITATIONS
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.
material shall include the following documents and tangible
things produced or otherwise exchanged:
produced by Defendants Bates-stamped AET003687-4134.
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.
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.
ACCESS TO AND USE OF ...