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Tetreault v. Standard Insurance Co.

United States District Court, W.D. Washington

February 21, 2018

MELISSA TETREAULT, Plaintiff,
v.
THE STANDARD INSURANCE COMPANY, an Oregon corporation, Defendant.

          David P. Roosa Attorneys for Plaintiff.

          Stacy M. Tucker Attorneys for Defendant.

          THIRD AMENDED STIPULATED PROTECTIVE ORDER

          Hon. Robert S. Lasnik, United States District Court Judge.

         The Parties agree to amend the previous stipulated protective order to include additional categories of document. Amendments are in bold and contained in section 2, below.

         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: [The parties must include a list of specific documents such as "company's customer list" or "plaintiffs medical records;" do not list broad categories of documents such as "sensitive business material"].

Claims manuals or similar documents by any other name, as they are proprietary business trade secrets; Training materials, as they are proprietary business trade secrets; Employee compensation plan information, as it is proprietary business trade secrets and its production potentially invades the privacy of third parties; Employee personnel file documents to the extent they are held to be relevant and discoverable by this Court, as the production of any such documents would invade the privacy of third parties to this action.
Plaintiffs private Facebook Messenger conversations, as they contain sensitive personal information about non-parties to this litigation, including minors, as well as HIPAA protected patient information, and sensitive personal information of 3rd parties.
Information related to Standard Insurance Company's relationship with MES or other third party vendors or independent medical providers, as those relationships constitute proprietary business trade secrets; Information related to Standard Insurance Company's aggregated claim numbers and statistics related to those claims to the extent they are held to be relevant and discoverable by this Court, as such information constitutes proprietary business trade secrets; Information related to Standard Insurance Company's electronic and paper record keeping practices, as they constitute proprietary business trade secrets.

         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 ...


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