United States District Court, W.D. Washington, Seattle
EMPLOYMENT ATTORNEYS LLP Kristi Favard, Attorneys for
KELLER CROMWELL LLP Paul R. Taylor, Attorneys for Defendant
Accreditation Council for Graduate Medical Education.
PEPPER LLP Michael K. Vaska, Rylan L.S. Weythman, Devra R.
Cohen, Attorneys for Defendant American Board of Thoracic
WRIGHT TREMAINE LLP Douglas C. Ross, David Maas, James
Corning, Attorneys for Defendants University of Washington
Medicine,, UWMedicine/NW, University of Washington Medical
Center, University, of Washington School of Medicine, Paul
Ramsey, M.D., Lester Permut, M.D., Seattle Children's
Hospital, Children's University Medical Group, Mary
Bridge Children's Foundation.
PATTERSON & MINES James D. Nelson, Natalie A. Moore,
Shaina R. Johnson, Attorneys for Defendant Thoracic Surgery
Directors Association, Inc.
[PROPOSED] PROTECTIVE ORDER
Robert S. Lasnik United States District Court Judge.
PURPOSES AND LIMITATIONS
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.
material shall include the following documents and tangible
things produced or otherwise exchanged:
• Any portions of applications to graduate medical
education programs, applications for hospital privileges,
personnel files, and other documents that contain sensitive
and/or personal identifying information, including but not
limited to social security numbers, sensitive personal
information, performance evaluations, and recommendation
• Competitively sensitive and/or proprietary
information, such as strategy documents showing thought
processes and decision making about services, business plans,
and/or third-party negotiations;
• Intellectual property, including trade secrets,
formulas, technology, designs, processes and production
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.
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.
ACCESS TO AND USE OF ...