United States District Court, W.D. Washington
Johnson Kerala Cowart Attorneys for Defendants
Whedbee Sam KramerAttorneys for Plaintiff
STIPULATED PROTECTIVE ORDER
S. Zilly United States District Judge.
PURPOSES AND LIMITATIONS
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.
material shall include the following documents and tangible
things produced or otherwise exchanged: (1) police personnel
files in whole or in part; (2) medical, psychological, and
financial records; (3) non-public tactical policies and
procedures and training protocols; and (6) records that could
implicate the privacy rights of the plaintiff or third
parties, including, but not limited to, personal identifying
information (“PII”) such as date(s) of birth,
social security number(s), personal home address(es), phone
number(s), and e-mail addresses; driver's license or
state identification number(s); personal financial
information; passport information; immigration status; and
criminal history and/or criminal record number(s).
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
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.
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:
receiving party's counsel of record in this action, as
well as employees of counsel to whom it is reasonably