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Chen v. D'Amico

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

February 15, 2018

SUSAN CHEN, et. al., Plaintiffs,
v.
NATALIE D'AMICO, et al., Defendants.

          DORSEY & WHITNEY LLP Shawn Larsen-Bright, WSBA # 37066 Nathan Alexander, WSBA #37040 T. Augustine Lo, WSBA # 48060 Court-Appointed Attorneys for Plaintiff Susan Chen, individually, and as FRCP 17 Guardian Ad Litem for Plaintiff JL

          OGDEN MURPHY WALLACE, PLLC Aaron P. Riensche, WSBA No. 3x7202 Geoff J. M. Bridgman, WSBA No. 25242 Daniel F. Shickich, WSBA No. 46479 Counsel for Defendants City of Redmond, E: cox.sarah@dorsey.com Natalie D 'Amico, Redmond Police Department, Ron Gibson, and Kristi Wilson

          MYERS & COMPANY, PLLC Michael David Myers, per email auth. Michael David Myers, WSBA No. 22486 Attorneys for Plaintiff Naixiang Lian, individually, and as FRCP 17 Guardian Ad Litem for Plaintiff LL

          ASSISTANT ATTORNEY GENERAL Scott M. Barbara, WSBA No. 20885 Counsel for DSHS, Kimberly Danner, Timothy, Earwood, Jill Kegel, Bill Moss, Kevin Quigley, and Tom Soule

          MODEL STIPULATED PROTECTIVE ORDER

          HONORABLE JAMES L. ROBART UNITED STATES DISTRICT COURT JUDGE

         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

         2.1 "Confidential" material shall include the following documents and tangible things produced or otherwise exchanged:

a) The complete Child Protective Services file of Naixiang Lian;
b) The complete FamLink file of Naixiang Lian;
c) The Hand in Hand Child Placing Agency file;
d) The Brekke-Hastings Foster Home file;
e) The Gonzarelli Foster Home file;
f) The Hoekema Foster Home file;
g) The Traverniti Foster Home file;
h) The White Foster Home file; and
i) Medical or health records, reports, documents, information or data; other documents or information containing confidential personal identifiers or other sensitive financial or personal information; and other similarly sensitive confidential, proprietary, or private material that is maintained in confidence, is not publicly available, and cannot be ascertained from publicly-available sources.

         2.2 Confidential material subject to redaction from documents and other tangible things produced or otherwise exchanged, explanation for which shall appear in a legend, privilege log, ...


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