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Wilcox v. Swapp

United States District Court, E.D. Washington

March 21, 2018

JADE WILCOX on behalf of herself and all others similarly situation, Plaintiff,
v.
JAMES CRAIG SWAPP, individually; and SWAPP LAW, PLLC, doing business as Craig Swapp and Associates, Defendants.

          PROTECTIVE ORDER

          ROSANNA MALOUF PETERSON, UNITED STATES DISTRICT JUDGE

         1. PURPOSES AND LIMITATIONS

         Disclosure and discovery in this action are 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 Stipulated Protective Order 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.

         2. "CONFIDENTIAL" MATERIAL

         a. "Confidential" material shall include the following documents and tangible things produced or otherwise exchanged: documents containing information that is not publicly known and is of commercial value, documents containing sensitive personal information, or documents containing information required by law or agreement to be kept confidential. The parties agree that "Confidential" materials shall include but shall not be limited to, (1) Collision Reports obtained from the Washington State Patrol, containing any person's photograph, social security number, driver identification number, name, address, telephone number, or date of birth; (2) documents that refer or relate to personal information obtained from Collision Reports, which can be used to identify an individual, including an individual's photograph, social security number, driver identification number, name, address, telephone number, or date of birth; or (3) documents that reference any person's or entity's private financial information, including but not limited to bank account information, salary information, and information concerning business profits, revenues, and/or expenses.

         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 at a location and in a secure manner that ensures that access is limited to the persons authorized under this agreement.

         4.2 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 Confidential material 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. Such Confidential material may be disclosed only to the categories of persons and under the conditions described in this Order. When the litigation has been terminated, a receiving party must comply with the provisions of section 10 below.

         Confidential material may be disclosed only to the following:

(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 litigation;
(b) the receiving party;
(c) experts and consultants to whom disclosure is reasonably necessary for this litigation and who have signed the "Acknowledgment and Agreement to ...

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