United States District Court, W.D. Washington, Seattle
CONNIE HARRIS, KRISTI SCOCCO, SUSAN SARTAIN, MARY MIHOVILICH, DAVID ASUNCION, BRIAN JAEGER, JUDY JAEGER, MARY CANTU, KRISTEN WEISE, KATRINA JOHNSON, CATHERINE CLEMENS, MARK MILLER, MARY MIOTKE, DALE DOYON, AARON HEINTZMAN, SARA MCNAMARA, ERIN BAST, and MARIA SAGISI GEISS, as individuals, Plaintiffs,
U.S. BANKCORP, BANK OF AMERICA, N.A., & KEYCORP, national banking associations, Defendants.
HARRISON ATTORNEY FOR PLAINTIFF
LARSEN-BRIGHT ALEX JOHNSTON ATTORNEYS FOR DEFENDANT U.S. BANK
SHANNON L. MCDOUGALD TRENT M. LATTA ATTORNEYS FOR DEFENDANT
FOLGER DERIC LATENDRESSE ATTORNEYS FOR DEFENDANT BANK OF
MODEL STIPULATED PROTECTIVE ORDER
Barbara Jacobs Rothstein U.S. District Court 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 be limited to non-public information,
documents, and tangible things that the producing party or
non-party reasonably and in good faith believes to be
private, personal, confidential, proprietary, trade secret,
and/or commercially sensitive, such that protection from
public disclosure is warranted. Confidential material shall
include non-public banking information, financial
information, tax information, personal records, confidential
internal business records, trade secrets, proprietary data,
employment information, personal identification information,
and other similarly sensitive information that the producing
party or non-party must keep in confidence or as to which
disclosure could result in injury, and which is not publicly
known and cannot be ascertained from information that is
readily available to the public. Confidential material
specifically includes here banking and financial information
of plaintiffs and defendants.
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