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Edge v. City of Everett

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

November 13, 2017

JOVANNA EDGE, et al., Plaintiffs,
v.
CITY OF EVERETT, a Washington Municipal Corporation, Defendant.

          Newman Du Wors LLP Keith Scully Derek A. Newman, WSBA No. 26967 Attorneys for Plaintiffs

          Pacifica Law Group Sarah C. Johnson Mathew J. Segal, WSBA #29797 Sarah S. Washburn, Sarah C. Johnson, WSBA #34529 Attorneys for Defendant

          STIPULATED PROTECTIVE ORDER

          MARSHA J. PECHMAN UNITED STATES DISTRICT JUDGE

         In accordance with LCR 26(c)(2) the Parties submit this Stipulated Protective Order. Based upon the representations and submissions of the parties, the Court's records and files in this matter, and good cause appearing therefore, the Court enters the following Protective Order (hereinafter “Order” or “Protective Order”) to govern the discovery, use, and handling of Protected Material produced by parties and non-parties in the above-captioned case. IT IS HEREBY ORDERED that:

         1. PURPOSE 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: Photographs and other visual depictions that might embarrass or expose the person depicted to criticism or ridicule, as designated by Plaintiffs; physical and email or social media identifying information that would allow persons to identify the residence or name of confidential social media accounts; confidential pricing and business information belonging to plaintiffs; certain law enforcement information and data in the possession of the City of Everett; certain business records of Plaintiffs; documents exempt under the Washington Public Records Act, chapter 42.56 RCW; materials subject to LCR 5.2(a).

         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” Information or Items: Unless otherwise ordered by the court or permitted in writing by the designating party, a receiving party may disclose any confidential material only to:

(a) the 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;
(b) the 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 material produced ...

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