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Espinoza v. The City of Seattle

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

July 2, 2018

DANIEL ESPTNOZA, Plaintiff,
v.
THE CITY OF SEATTLE, WASHINGTON, and LIEUTENANT THOMAS MAHAFFEY, individually, Defendants,

          PETER S. HOLMES Seattle City Attorney DAVID BOWMAN, ANDREA SCHEELE, Assistant City Attorneys Attorneys for Defendants.

          LAW OFFICE OF THOMAS G. JARRARD, PLLC THOMAS G. JARRARD, CROTTY & SON LAW FIRM, PLLC MATTHEW Z. CROTTY, JOHN T LAW, PLLC JOHN M. TYMCZYSZYN, Attorneys for Plaintiff.

          STIPULATION AND ORDER FOR PROTECTION OF CONFIDENTIAL DISCOVERY DOCUMENTS

          James L. Rot art, Judge U.S. District Court.

         THE PARTIES, Plaintiff Daniel Espinoza, represented by Thomas G. Jarrard, Matthew Z. Crotty and John M. Tymczyszyn, and Defendant City of Seattle, represented by Assistant City Attorneys David Bowman and Andrea Scheele, stipulate and agree to the terms and procedures set forth in the below Protective Order for designating and protecting confidential information, DATED this 28th day of June, 2018.

         ORDER

         Based on the foregoing stipulation of the parties and good cause appearing, NOW, THEREFORE, IT IS ORDERED that the parties to the above-captioned case shall disclose documents designated as confidential subject to the following terms and conditions:

         1. The Documents may contain or refer to sensitive confidential information, including medical information, personnel files containing benefit and beneficiary information, discipline, performance evaluations, investigations of claims and other documents that would normally not be available to persons other than the employee and the supervisory chain for such employee. If disclosed other than as provided in this Protective Order, such information could result in invasion of the privacy of non-litigants. In order that all parties may obtain evidence in this case, it is necessary to make such Documents and discovery available to counsel of record and others while protecting each party against unnecessary disclosure of private and confidential information. Consequently, no Documents or discovery or copies of Documents or discovery designated confidential by this Order shall be delivered to any person except as provided in paragraphs 6, 8 and 9. Neither the contents nor substance of any such Document or discovery shall be revealed except to persons authorized by paragraphs 7, 9 and 10 of this Order.

         All persons bound by this Protective Order shall maintain confidentiality, both during and after disposition of this case.

         2. As used herein, the term "CONFIDENTIAL" is defined as follows:

a. Any Document which is marked as such by stamping the cover or first page of each such Document with the word "CONFIDENTIAL." Some documents stamped "CONFIDENTIAL" may also be marked 'ATTORNEY'S EYES ONLY," in which case they shall only be disclosed to individuals described in section 6 b-f of this Order. All copies of materials so marked shall also be stamped "CONFIDENTIAL" and dated if the duplicating process by which copies are made does not produce the original stamp. The person designating Documents as "CONFIDENTIAL" shall be deemed the "Designating Person" for purposes of this Protective Order. If any Document so designated becomes publicly available through no fault of a recipient of such Document pursuant to this Order, then the document will lose its "CONFIDENTIAL" status.
b. Any deposition designated by any person as "CONFIDENTIAL" at any time during the deposition or upon the conclusion of the deposition, as set forth below. Any depositions so designated shall be marked "CONFIDENTIAL" by the court reporter on all transcripts and on the original, c. Documents or testimony designated "CONFIDENTIAL" are expressly subject to this Court's ruling on their confidentiality.

         3. Nothing in this Order shall require any person to treat as "CONFIDENTIAL" any material or information which has not been so designated in accordance with this Order.

         4. The Parties agree, and the Court hereby orders, that each Designating Person shall exercise caution in designating any Document and any portion of a deposition as "CONFIDENTIAL." This category shall be reserved for Documents which contain information that most individuals would consider private and confidential information relating to employment and/or medical records. The City agrees that when determining which documents should be designated "CONFIDENTIAL," it will be guided by considerations of which documents may be exempt from disclosure or subject to redaction imder the Public Records Act.

         5. Each Designating Person may orally designate as "CONFIDENTIAL" any testimony during the course of a deposition that refers or relates to a confidential Document, in which case the court reporter shall transcribe the testimony so designated in a separate volume marked "CONFIDENTIAL." Counsel for all parties will receive copies of all answers, Documents and testimony designated "CONFIDENTIAL" or otherwise for their use. In any event, counsel shall have 15 days after receiving a deposition transcript to designate pages of the transcript (and exhibits thereto) as "CONFIDENTIAL." Until expiration of the 15-day period, the parties will treat the entire deposition as subject to protection against disclosure under this Order. If no party's counsel timely designates confidential information in a deposition in the manner described above, then none of the transcript or its exhibits will be treated as "CONFIDENTIAL." For the sake of ...


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