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State v. Horning Brothers, LLC

United States District Court, E.D. Washington

September 29, 2017

STATE OF WASHINGTON, Plaintiff,
v.
HORNING BROTHERS, L.L.C., and HERMILO CRUZ, in his individual capacity and as a member of the marital community of HERMILO CRUZ and CLAUDIA SANCHEZ, Defendants. SOCORRO DIAZ SILVAS, ROXANA RODRIGUEZ DE ALFARO, YESICA CABRERA NAVARRO, YASMIN CABRERA NAVARRO, and SAMANTHA MENDOZA, Plaintiffs-Intervenors,
v.
HORNING BROTHERS, L.L.C, Defendant.

          ROBERT W. FERGUSON Attorney General COLLEEN M. MELODY, PATRICIO A. MARQUEZ Assistant Attorneys General Civil Rights Unit.

          STIPULATED CONFIDENTIALITY AGREEMENT AND PROTECTIVE ORDER

          THOMAS O. RICE CHIEF UNITED STATES DISTRICT JUDGE.

         This is a joint agreement between: the State of Washington; Plaintiffs-Intervenors Socorro Diaz Silvas, Roxana Rodriguez de Alfaro, Yesica Cabrera Navarro, Yasmin Cabrera Navarro, and Samantha Mendoza; Defendant Horning Brothers, L.L.C.; and Defendant Hermilo Cruz (“the parties”). The parties expect that disclosure of documents in this case may involve the exchange of confidential information, as identified herein, that is covered by the scope of Federal Rule of Civil Procedure 26(c).

         Accordingly, the parties stipulate and agree to, and the Court finds good cause for, entry of this Confidentiality Agreement and Protective Order pursuant to Federal Rule of Civil Procedure 26(c).

         It is hereby ordered that:

         A. Designation of Confidential Information

         1. “Confidential Information” refers to any record, document, tangible thing, discovery response, testimony, information, or other material disclosed or to be disclosed through formal or informal discovery or otherwise in the course of this litigation that contains: physical and mental health information; personal and business financial and tax information; immigration information or status; home address, home phone number, cell phone number, or email address information; passport numbers, drivers' license numbers, resident identification numbers, social security numbers, or alien numbers; and birthdates.

         2. Any party may designate any record, document, tangible thing, discovery response, testimony, information, or other material as confidential. All documents, tangible things, discovery responses, testimony information, or other materials containing confidential information pursuant to this Order shall be marked “CONFIDENTIAL.” Such designation shall, without more, subject the information produced or provided under such designation to the provisions of this Confidentiality Agreement and Protective Order.

         3. Counsel for any party may designate deposition testimony or part of any deposition testimony as confidential by advising the court reporter and counsel of such designation during the course of the deposition.

         4. Confidential information includes all material designated confidential pursuant to the terms of this Order, as well as summaries and compilations derived from such confidential material, including but not limited to charts, tables, models, and textual summaries, to the extent that the material retains restricted information as defined by Paragraph A.1. above (i.e. “Confidential Information”).

         5. Inadvertent failure to designate a document as confidential may be corrected by supplemental written notice given as soon as practicable.

         6. The parties must have a good-faith basis in fact and in law to designate material as confidential.

         7. If any party objects to the designation of any information as confidential, that party shall confer with the party designating the information as confidential in an effort to resolve any dispute. If the parties are unable to resolve such dispute, the party designating the material as confidential may move to have the Court declare the contested information confidential.

         8. If non-confidential information is contained in or otherwise derived from confidential materials, any portion that consists solely of non-confidential information shall not be confidential for purposes of this Order.

         B. Treatment of ...


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