United States District Court, W.D. Washington, Seattle
V. Rocke, WSBA No. 31525 Peter Montine, WSBA No. 49815 Rocke
Law Group, PLLC Attorneys for Plaintiff.
Michael Reilly, WSBA No. 14674 Justin A. Okun Lane Powell PC
Attorneys for Defendant.
STIPULATED PROTECTIVE ORDER
C. COUGHENOUR UNITED STATES DISTRICT JUDGE.
to the parties' Stipulated Motion for Protective Order
(Dkt. No. 17), the Court ORDERS as follows:
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:
(a): Personnel files of non-parties;
(b): Investigations into claims of discrimination by other
employees of Defendant;
(c): Defendant's EEO-1 filings;
(d): Plaintiff's medical records; and
(e): Defendant's financial information.
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.
ACCESS TO AND USE OF CONFIDENTIAL MATERIAL
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 persons authorized under this agreement.
Disclosure of “CONFIDENTIAL” ...