United States District Court, W.D. Washington, Seattle
KEATING, BUCKLIN & McCORMACK, INC., P.S., Jeremy W.
Culumber Jeremy W. Culumber, WSBA #35423 Attorneys for
STIPULATION AND [PROPOSED] PROTECTIVE
L. Robart, United States District Judge
PURPOSES AND LIMITATIONS
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:
- Police Department Personnel Files for Officer Slade.
- Medical and Employment Records of Plaintiff, Carol Jones
protections conferred by this agreement cover not only
confidential material (as denned 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.
ACCESS TO AND USE OF CONFIDENTIAL MATERIAL
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. 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 person
authorized under this agreement.
Disclosure of "CONFIDENTIAL"
Information or Items.
otherwise ordered by the court or permitted in writing by the
designating party, a receiving party may disclose any
confidential material only to:
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;
officers, directors, and employees (including in-house
counsel) of the receiving party to whom disclosure is
reasonably necessary for this litigation, unless the parties
agree that a particular document or ...