Searching over 5,500,000 cases.


searching
Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.

Harris v. U.S. Bankcorp

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

May 29, 2019

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,
v.
U.S. BANKCORP, BANK OF AMERICA, N.A., & KEYCORP, national banking associations, Defendants.

          ERIC HARRISON ATTORNEY FOR PLAINTIFF

          SHAWN LARSEN-BRIGHT ALEX JOHNSTON ATTORNEYS FOR DEFENDANT U.S. BANK NATIONAL ASSOCIATION

          SHANNON L. MCDOUGALD TRENT M. LATTA ATTORNEYS FOR DEFENDANT KEYCORP.

          KELLY FOLGER DERIC LATENDRESSE ATTORNEYS FOR DEFENDANT BANK OF AMERICA, N.A.

          MODEL STIPULATED PROTECTIVE ORDER

          Barbara Jacobs Rothstein U.S. District Court Judge.

         1. PURPOSES AND LIMITATIONS

         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 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.

         2. “CONFIDENTIAL” MATERIAL

         “Confidential” 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.

         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. ACCESS TO AND USE OF CONFIDENTIAL MATERIAL

         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 ...


Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.