United States District Court, W.D. Washington, Seattle
Crawford LAW OFFICE OF MEL CRAWFORD Attorney for Plaintiff
SCHWABE, WILLIAMSON & WYATT, P.C. Farron Curry, Alison
Lima Andersen (pro hac vice), Brandi G. Howard (pro hac vice)
ARENT FOX LLP Attorneys for Defendants
ORDER GRANTING JOINT MOTION FOR PROTECTIVE
J. Pechman, United States District Judge.
PURPOSES AND LIMITATIONS
believe that discovery in this action is likely to involve
production of confidential, proprietary, or private
information for which special protection may be warranted.
While Plaintiff does not agree, she will not oppose
Defendants' petition to enter the following 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.
material shall include the following documents and tangible
things produced or otherwise exchanged: documents that make
up the administrative record, medical records,
personnel/employment performance records, and proprietary
internal policies and procedures.
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.
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.
ACCESS TO AND USE OF CONFIDENTIAL MATERIAL
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.
Disclosure of “CONFIDENTIAL” Information or
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 ...