United States District Court, W.D. Washington, Seattle
LISA R. MAURICE, Plaintiff,
DAVID SHULKIN, et al., Defendants.
ANNETTE L. HAYES United States Attorney SARAH K. MOREHEAD,
WSBA #29680 Assistant United States Attorney Attorney for
CHRISTOPHER J. STOCKWELL, WSBA #50001 Attorney at Law
Stockwell Law Firm, PLLC Attorney for Plaintiff.
STIPULATED PROTECTIVE ORDER
S. ZILLY, UNITED STATES DISTRICT 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: (1) medical records
and medical information, (2) personnel and employment-related
records of any current or former government employee, (3) tax
records, (4) documents related to any other current or former
government employee's protected activity, and (5) any
other records whose release without a protective order would
potentially violate the Privacy Act, 5 U.S.C. § 552a.
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.
ACCESS TO AND USE OF CONFIDENTIAL MATERIAL
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 at a location and in a secure
manner that ensures that access is limited to the persons
authorized under this agreement.
Disclosure of “CONFIDENTIAL” Information or
Items. Unless otherwise ordered by the court or
permitted in writing by the designating party, a receiving
party may disclose any confidential material only to:
(a) the receiving party's counsel of record in this
action, as well as employees of counsel to whom it is
reasonably necessary to disclose the information for this
(b) the officers, directors, and employees (including in
house counsel) of the receiving party to whom disclosure is
reasonably necessary for this litigation, unless the parties
agree that a particular document or material produced is for
Attorney's Eyes Only and is so designated;
(c) experts and consultants to whom disclosure is reasonably
necessary for this litigation and who have signed the
“Acknowledgment and Agreement ...