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Flowers v. Fred Hutchinson Cancer Research Center

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

November 2, 2017

JON FLOWERS, Plaintiff,
v.
FRED HUTCHINSON CANCER RESEARCH CENTER, Defendant.

          Aaron V. Rocke, WSBA No. 31525 Peter Montine, WSBA No. 49815 Rocke Law Group, PLLC Attorneys for Plaintiff.

          D. Michael Reilly, WSBA No. 14674 Justin A. Okun Lane Powell PC Attorneys for Defendant.

          STIPULATED PROTECTIVE ORDER

          JOHN C. COUGHENOUR UNITED STATES DISTRICT JUDGE.

         Pursuant to the parties' Stipulated Motion for Protective Order (Dkt. No. 17), the Court ORDERS as follows:

         1. PURPOSES AND LIMITATIONS

         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.

         2. “CONFIDENTIAL” MATERIAL

         “Confidential” 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.

         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. ACCESS TO AND USE OF CONFIDENTIAL MATERIAL

         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. 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” ...


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