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.

Aikens v. Panatte, LLC

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

May 10, 2018

DELIA AIKENS, on behalf of herself and other similarly situated, Plaintiff,
v.
PANATTE, LLC, LAND HOME FINANCIAL SERVICES, INC., AND MORTGAGE DEFAULT SERVICES, LLC, Defendants.

          DC Law Group NW, LLC Matthew J. Cunanan, WSBA#42530 Drew Davis, WSBA#47297 Christopher Wieting, WSBA#48207 MilenaVill, WSBA#51231 DC LAW GROUP N.W. LLC Jesse S. Johnson (pro hac vice) Greenwald Davidson Radbil PLLC Attorneys for Plaintiff

          CALFO EAKES & OSTROVSKY PLLC Andrea Delgadillo Ostrovsky, WSBA# 37749 WEINER BRODSKY KIDER PC Michael Y. Kieval, pro hac vice Attorney for Defendant Land Home Financial Services, Inc.

          STIPULATED [EROPOSED] PROTECTIVE ORDER

          HONORABLE ROBERT S. LASNIK UNITED STATE DISTRICT COURT JUDGE

         1. STIPULATIONS

         The parties hereby stipulate to and petition the court to enter the following Stipulated Protective Order regarding discovery that relates to confidential, personal, business and other proprietary information. 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" AND "ATTORNEY'S EYES ONLY" MATERIAL

         "Confidential" and/or "Attorney's Eyes Only" material means information or tangible things that qualify for protection under Federal Rule of Civil Procedure 26(c) and as described above in Stipulations, including, but not limited to, the following:

(a) Information constituting sensitive "nonpublic personal information" within the meaning of the Gramm-Leach-Bliley Act, 15 U.S.C. § 6802, et seq. and its implementing regulations, including, but not limited' to, financial, tax, banking, or credit information for any person, together with personally identifiable information with respect to such person, including, but not limited to, name, address, Social Security number, loan number, telephone number, or place or position of work;
(b) Information regarding trade secrets, confidential business practices, or other confidential research, development, or commercial information otherwise generally unavailable to the public, including but not limited to materials related to company policies, procedures, corporate governance, employee training materials, employee personnel records and other non-public internal company files.

         3. SCOPE

         The protections conferred by this agreement cover not only material designated as "Confidential" and/or "Attorney's Eyes Only" (as defined above), but also (1) any information copied or extracted from material designated as "Confidential" and/or "Attorney's Eyes Only"; (2) all copies, excerpts, summaries, or compilations of such material; and (3) any testimony, conversations, or presentations by parties or their counsel that might reveal such 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 and/or Attorney's Eyes Only 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" And/Or "Attorney's Eyes Only" Information or Items. Unless otherwise ordered by the court or permitted in writing by the designating party, a receiving party may disclose any such 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 ...

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.