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Johnson v. Providence Health & Services

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

June 4, 2018

JENNY JOHNSON, individually and on behalf of a class of persons similarly situated, and on behalf of the Providence Health & Service 403b Value Plan, Plaintiff,

          Mark K. Gyandoh (admitted pro hac vice) Attorney for Plaintiff

          Cliff Cantor, WSBA # 17893 Attorney for Plaintiff

          Meaghan VerGow (admitted pro hac vice) Attorney for Defendants



         This matter comes before the Court on the Parties stipulated protective order (Dkt. No. 42). Pursuant to the parties' stipulation, the Court ORDERS as follows:


         The Parties acknowledge that 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 Local Civil Rule 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.


         “Confidential” material shall include any document, material, or information supplied in any form, or any portion thereof, which contains confidential or proprietary business, commercial, research, personal, personnel, process, product, or financial information of the producing party or non-party, including, without limitation, discussions of business operations, processes, and procedures; personally identifiable information such as social security numbers; proprietary software or systems; proprietary edits or customizations to software; proprietary product information; margin, cost, and pricing information; trade secrets; confidential research and analysis; board materials, discussions, and presentations; executive or committee meeting minutes, materials, discussions, and presentations; interactions with government regulatory bodies; negotiation strategies; information or data relating to strategic plans; data received from a non-party pursuant to a current Non-Disclosure Agreement; commercial agreements; settlement negotiations; and settlement agreements; and Plaintiff's investment balances in the Plan, the account or routing numbers of any of Plaintiff's bank or retirement accounts, her address, her employment or personnel file and any other information protected under Federal Rule of Civil Procedure 5.2. A designation by a party or non-party of Confidential Information shall constitute a representation to the Court that such party or non-party believes in good faith that the information constitutes Confidential Information. The parties and non-parties shall make a good-faith effort to designate information only as needed.

         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.


         4.1 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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