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Karnoski v. Trump

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

February 14, 2018

RYAN KARNOSKI, et al., Plaintiffs, STATE OF WASHINGTON, Plaintiff-Intervenor,
v.
DONALD TRUMP, et al., Defendants.

          NEWMAN DU WORS LLP Derek A. Newman, WSBA #26967 LAMBDA LEGAL DEFENSE AND EDUCATION FUND, INC. Camilla B. Taylor Tara L. Borelli, WSBA #36759 Peter C. Renn Natalie Nardecchia Sasha Buchert Kara N. Ingelhart Carl Charles

          OUTSERVE-SLDN, INC. Peter Perkowski KIRKLAND & ELLIS LLP James F. Hurst, P.C. Jordan Heinz Scott Lerner Vanessa Barsanti Daniel Siegfried Ben Tyson Attorneys for Plaintiffs

          UNITED STATES DEPARTMENT OF JUSTICE Ryan B. Parker Gerald Brinton Lucas Andrew Carmichael United States Department of Justice Civil Division, Federal Programs Branch Attorneys for Defendants

          OFFICE OF THE ATTORNEY GENERAL La Rond Baker Colleen Melody Assistant Attorney General Office of the Attorney General Counsel for Intervenor Plaintiff State of Washington

          STIPULATED UNIFORM PROTECTIVE ORDER AND CROSS-USE AGREEMENT

          Marsha J. Pechman United States District Judge

         The Honorable Marsha J. Pechman Pursuant to Federal Rule of Civil Procedure 26(c) and 5 U.S.C. § 552a(b)(11), and for good cause shown, the Court hereby enters the following Stipulated Uniform Protective Order and Cross-Use Agreement:

         WHEREAS, pursuant to discovery or otherwise during the course of the above-captioned action (“Karnoski v. Trump”); Doe v. Trump, No. 1:17-cv-1597 (D.D.C.); Stone v. Trump, No. 1:17-cv-02459 (D. Md.); and Stockman v. Trump, No. 17-cv-1799 (C.D. Cal.); (collectively, the “Named Actions”); the parties may be required to disclose confidential and sensitive information within the meaning of Rule 26(c) of the Federal Rules of Civil Procedure and information subject to the Privacy Act; and

         WHEREAS, a protective order pursuant to Rule 26(c) and 5 U.S.C. § 552a(b)(11) is necessary in the Named Actions to prevent unnecessary disclosure or dissemination of such confidential and sensitive information held by the parties;

         WHEREAS, there exists substantial overlap between the subject matter of the Named Actions, making it efficient and appropriate to permit discovery produced by parties and non-parties in any of the Named Actions to be used in Karnoski v. Trump;

         THEREFORE, IT IS HEREBY ORDERED that the following provisions of this Uniform Protective Order and Cross-Use Agreement (hereafter the “Order”) shall control the disclosure, dissemination, and use of material produced in discovery in Karnoski v. Trump:

         1. Scope of Order: This Order shall govern the production, use, and disclosure of all information and materials produced by any party or non-party in response to any discovery request in Karnoski v. Trump (including, but not limited to, documents, interrogatory answers, responses to requests to admit, and deposition transcripts and exhibits), all information contained in those materials, and all copies, excerpts, or summaries of those materials (collectively, “Discovery Material”).

         2. Designation of Protected Material: A party or non-party may, in good faith, designate as CONFIDENTIAL and therefore subject to the protections and requirements of this Order, any Discovery Material that the designating party reasonably believes contains confidential information, including personal, proprietary, or sensitive information not generally disclosed to the public. Subject to the exceptions set forth in Paragraph 6, Discovery Material designated CONFIDENTIAL (“Protected Material”) shall be used by the receiving parties solely for the prosecution or defense of the Named Actions and shall not be disclosed to any person or entity unless specifically authorized by the terms of this Order or by further order of the Court. Consistent with the requirements of this paragraph, a party may, within fifteen (15) business days of receipt of the Discovery Materials, by written notice to the other parties, designate as CONFIDENTIAL any Discovery Materials produced or given by the other parties or by a non-party but not designated CONFIDENTIAL by that other party or non-party.

         3. Limitations on Use: Subject to the exceptions set forth in Paragraph 6, Protected Material and its contents, as well as copies, summaries, notes, memoranda, and computer databases relating thereto, shall be used solely for the purpose of the Named Actions, shall be and remain confidential, and shall not be disclosed in any fashion, nor be used for any purpose other than litigating the Named Actions.

         4. Limited Disclosure of Protected Material: Except as stated in paragraphs 5 and 6 below, Protected Material may be disclosed, subject to the specific procedures and provisions contained in ...


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