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Rosenberg v. CCS Commercial, L.L.C.

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

September 18, 2017

CCS COMMERCIAL, L.L.C. d/b/a Credit Collection Services Commercial, and PROGRESSIVE DIRECT INSURANCE COMPANY Defendants.

          TOUSLEY BRAIN STEPHENS Chase Christian Alvord, Matthew James Ide Attorneys for Ayanna Rosenberg, individually, and on Behalf of all those similarly situated

          HOLLAND & KNIGHT LLP Shannon Armstrong, WSBA #45947 Attorney for Progressive Direct Insurance Company

          COZEN O'CONNOR Kevin A Michael Nadia Bugaighis William Harrison Walsh Attorney for CCS Commercial, LLC


          Marsha J. Pechman United States District Judge


         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.


         “Confidential” material shall include the following documents and tangible things produced or otherwise exchanged: claims materials, documents containing personal identifying information of insureds, documents containing personal health information, documents containing personal financial information, documents containing proprietary or competitive business information regarding business practices, policies and sales, documents containing financial and pricing information, and documents containing business information of third parties.

         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.


         4.1 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 and under the conditions described in this agreement, unless and until the restrictions in this Stipulated Protective Order are removed or modified either by agreement of the parties or by order of the Court. 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 agreement.

         4.2 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 litigation;
(b) each party to this action, including the officers, directors, and employees (including in house counsel) of the receiving party to whom disclosure is reasonably necessary for this litigation;
(c) experts and consultants to whom disclosure is reasonably necessary for this litigation and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
(d) the court, court personnel, and court reporters and their staff;
(e) copy or imaging services retained by counsel to assist in the duplication of confidential material or any person retained or used by counsel for any part to assist counsel with respect to this action, provided that counsel for the party retaining the service or person instructs the service or person not to disclose any confidential material to third parties and to immediately return all originals and copies of any confidential material;
(f) during their depositions, witnesses in the action to whom disclosure is reasonably necessary and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise agreed by the designating party or ordered by the court. Pages of transcribed deposition testimony or exhibits to depositions that reveal confidential material must be separately bound by the court reporter and may not be disclosed to anyone except as permitted under this agreement;
(g) the author or recipient of a document containing the information or a custodian or other person who otherwise possessed or knew the information
(h) any person whom the parties agree, in advance and in writing, may receive such discovery materials;
(i) any arbitrator, mediator, or discovery referee in this litigation, and employees and similar personnel of said arbitrator, mediator or discovery referee.

         No person authorized under Paragraphs 6(c), (f), and (h) of this Stipulated Protective Order to receive access to “CONFIDENTIAL” discovery materials shall be granted such access until such person has received a copy of this Stipulated Protective Order and agrees in writing to be bound by it by signing a copy of the agreement attached as Exhibit A to this Stipulated Protective Order. The original of each such written agreement shall be maintained by counsel for the party that seeks to disclose “CONFIDENTIAL” discovery materials pursuant to Paragraph 4.2. Further, each recipient of “CONFIDENTIAL” discovery materials ...

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