Searching over 5,500,000 cases.


searching
Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.

Boule v. Egbert

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

March 6, 2018

ROBERT BOULE, Plaintiff,
v.
ERIK EGBERT, et. al., Defendants.

          ANNETTE L. HAYES United States Attorney KRISTIN B. JOHNSON WSBA #28189 Assistant United States Attorney Attorney for U.S. Customs and Border Protection

          BREEAN L. BEGGS, WSBA #20795 Paukert & Troppmann, PLLC Attorney for Plaintiff Robert Boule

          MILLS MEYERS SWARTLING P.S. GEOFFREY M. GRINDELAND, WSBA # 35798 NIKKI C. CARSLEY, WSBA # 46650 Attorneys for Agent Egbert

          STIPULATED PROTECTIVE ORDER BETWEEN PARTIES, U.S. CUSTOMS AND BORDER PROTECTION AND U.S. IMMIGRATION AND CUSTOMS ENFORCEMENT

          RICARDO S. MARTINEZ, CHIEF UNITED STATES DISTRICT JUDGE

         Discovery in this action is likely to involve production of confidential, proprietary, or private information for which special protection may be warranted. Specifically, Plaintiff and Defendant seek discovery of records pertaining to individuals in a “system of records, ” as defined by the Privacy Act, 5 U.S.C. § 552a(a)(5) (the “Act”), disclosure of which would potentially constitute a violation of criminal and civil law under section 552a(b) of the Act, absent an Order from this Court pursuant to section 552(b)(11) of the Act. Furthermore, since disclosure of such records for purposes other than this litigation could reasonably be expected to constitute an unwarranted invasion of privacy, the parties and U.S. Customs and Border Protection (“CBP”) and U.S. Immigration and Customs Enforcement (“ICE”) hereby stipulate to and respectfully request that this Court enter the following Stipulated Protective Order restricting the use of such information for purposes of this litigation only.

         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 and CBP and ICE hereby stipulate to and petition the court to enter the following Stipulated Protective Order. The parties and CBP and ICE 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:

         (a) internal CBP and ICE records including, but not limited to, personnel records, medical records, law enforcement records, investigative records, legal records, disciplinary records, and pay/benefits/leave records;

         (b) records provided to CBP and ICE, or obtained by CBP and ICE, from other federal, state, or local agencies or organizations;

         (c) any information that the producing party is obligated by contract or state or federal law to keep confidential;

         (d) Plaintiff's medical records; Plaintiff's tax records;

         (e) Agent Egbert's employment records, including job applications, performance reviews, materials created during any internal-affairs investigation, and any disciplinary records;

         (f) Agent Egbert's insurance records, including insurance policies; communications between the parties and the federal government; and any other document a party designates as confidential.

         Other than protection of Privacy Act protected information, nothing in this Order limits in any way any other restrictions on the release of information, including restrictions on release of ...


Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.