United States District Court, W.D. Washington
Sullivan Law Firm Kevin P. Sullivan, Mina Shahin, Attorneys
MALTZMAN & PARTNERS, PA Jeffrey Maltzraan, Edgar R. Nield
Attorneys for Defendant.
STIPULATION FOR CONFIDENTIALITY AND PROTECTIVE
HONORABLE ROBERT S. LASNIK, JUDGE.
HEREBY STIPULATED by all parties to this action, by and
through their attorneys of record, that in order to protect
the confidentiality of the identity of Plaintiff, certain
records disclosed in this action bearing Plaintiffs name,
date of birth, social security number, or other identifying
information will be designated as Confidential Material.
Those records shall include but not be limited to the
a. Any and all of Plaintiffs medical and psychological
treatment records and bills;
b. Any tax record information pertaining to Plaintiff,
including paystubs, W2 forms, job applications, tax returns,
and correspondences between Plaintiff and tax preparers or
state and federal tax authorities;
c. Any of Plaintiffs job application or personnel files for
d. Any records of criminal arrests or convictions;
e. Any credit or property ownership histories ore credit card
f. All reports or photographs concerning or depicting