United States District Court, E.D. Washington
W. FERGUSON Attorney General COLLEEN M. MELODY, PATRICIO A.
MARQUEZ Assistant Attorneys General Civil Rights Unit.
STIPULATED CONFIDENTIALITY AGREEMENT AND PROTECTIVE
O. RICE CHIEF UNITED STATES DISTRICT JUDGE.
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).
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
hereby ordered that:
Designation of Confidential Information
“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.
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.
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.
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
Inadvertent failure to designate a document as confidential
may be corrected by supplemental written notice given as soon
parties must have a good-faith basis in fact and in law to
designate material as confidential.
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
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.
Treatment of ...