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Williams v. King County

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

April 18, 2018

TYRONE WILLIAMS, Plaintiff,
v.
KING COUNTY, a political subdivision of the State of Washington; CITY OF SEATAC, a municipal corporation; SEATAC POLICE DEPARTMENT; KING COUNTY SHERIFF'S DEPARTMENT; BRIAN BELONGIA and Jane Doe and the marital community composed thereof, Defendants.

          MATTHEW D. HARTMAN, Attorney for Plaintiff Tyrone Williams

          DANIEL L. KINERK, Attorney for Defendants King County, SeaTac Police, City of SeaTac, King County Sheriff's Department, and Brain Belongia

          STIPULATED PROTECTIVE ORDER REGARDING CONFIDENTIALITY

          THOMAS S. ZILLY UNITED STATES DISTRICT JUDGE.

         1. PURPOSES AND LIMITATIONS

         Discovery in this action is likely to involve production of confidential or private information for which special protection may be warranted, including information that is exempt from public disclosure and non-public records as they relate to the King County Sherriff's Department, SeaTac Police Department, and Brian Belongia. 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 CR 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 will include the following documents, electronically stored information (ESI) and tangible things produced or otherwise exchanged:

a. King County's personnel and employee home addresses, dates of birth, social security numbers; and names of dependents;
b. King County personnel and employee employment applications, tests, payroll records and performance evaluations, except if there are specific instances of misconduct or discipline; and medical files;
c. Any other material enjoying special legal protection from disclosure that is relevant to this case.

         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. In addition, these protections do not apply to information that is already in the public record, such as in a publicly accessible court file or trial transcript.

         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 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 ...

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