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C.V. v. Corporation of The President of The Church of Jesus Christ

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

April 24, 2018

C.V., individually; and M.H., individually, Plaintiffs,
v.
CORPORATION OF THE PRESIDENT OF THE CHURCH OF JESUS CHRIST OF LATTER-DAY SAINTS, Defendant.

          GORDON TILDEN THOMAS & CORDELL LLP Jeffrey I. Tilden, Michael Rosenberger, Attorneys for Defendant

          WASHINGTON LAW CENTER Ashton K. Dennis, Daniel Swinford, Attorneys for Plaintiffs

          CONNELLY LAW OFFICES Lincoln C. Beauregard, Connelly Law Offices Attorneys for Plaintiffs

          STIPULATED PROTECTIVE ORDER

          THE HONORABLE JAMES ROBART, UNITED STATES DISTRICT COURT JUDGE.

         [Identical to the Western District of Washington Model Order, with Particular Types of Materials Described in Section 2 as Called for by the Model Order]

         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 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.

         2. "CONFIDENTIAL" MATERIAL

         "CONFIDENTIAL" material shall include the following documents and tangible things produced or otherwise exchanged: (1) documents that contain personal information in COP's possession relating to third-parties who are members of the LDS Church; and (2) copyrighted Church Handbooks and other internal documents that provide guidance for clergy in the LDS Church.

         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 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 litigation;
(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 ...

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