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P.B. v. Marcotte

United States District Court, W.D. Washington

May 31, 2019

P.B.; and N.W., minors, Plaintiff,
v.
COREY MARCOTTE and KING COUNTY, Defendant.

          David J. Hackett, Attorney for Defendant King County

          David Whedbee, Joe Shaeffer, Attorneys for Plaintiffs

          Geoff Grindeland, Nikki Carsley, Attorneys for Deputy Marcotte

          STIPULATED PROTECTIVE ORDER

          THE HONORABLE ROBERT S. LASNIK JUDGE.

         Pursuant to FRCP 26(c), the parties to this action, by and through their respective counsel, hereby stipulate to the entry of this Protective Order Concerning Confidential Information ("Protective Order"), as follows:

         1. This Protective Order shall apply to all documents, materials, and information designated as "CONFIDENTIAL" pursuant to the terms of this Protective Order, unless the "CONFIDENTIAL" designation has been withdrawn by the designating party or by Order of the Court, including without limitation, documents produced, answers to interrogatories, responses to requests for admission, deposition testimony, and other information disclosed pursuant to the disclosure or discovery duties created by the Civil Rules.

         2. As used in this Protective Order, "document" is defined as provided in FRCP 34(a)(1)(A). A draft or non-identical copy is a separate document within the meaning of this term.

         3. "CONFIDENTIAL" information covered under the terms of this Protective Order shall include the following documents, materials, and/or information produced or otherwise exchanged by Plaintiffs P.B and N.W., minors ("Plaintiffs"), Defendants King County and Deputy Marcotte ("Defendants"), and/or any of Plaintiffs' or Defendants' agents or representatives, when designated as "CONFIDENTIAL:"

         (a) Protected Health Information ("PHI") as defined by the Health Insurance Portability and Accountability Act ("HIPAA"); medical information, such as medical records, medical treatment, medical diagnoses, and drug recommendations or prescriptions; medical billing information; and investigations and statements to the extent they include the same;

         (b) the financial status of Plaintiff and/or Defendants, including but not limited to any nonpublic financial information such as tax records, profit and loss statements, accounting documents, reports, or assessments; business and contractual relationships; financial contracts; and investigations and statements related to the same, excluding any such documents already in the public domain;

         (c) Contracts and other business documents subject to reasonable confidentiality or nondisclosure agreements; leases; and any other document that the parties stipulate is a confidential business document;

         (d) Information or documents obtained from third parties falling into the foregoing categories; and

         (e) Confidential employment or personnel information involving employees or former employees of Defendant, including but not limited to information regarding such individuals' hiring, job performance, discipline, termination of employment, or compensation or benefits.

         4. The protections conferred by this agreement cover not only CONFIDENTIAL information (as defined above), but also (1) any information copied or extracted from confidential information; (2) all copies, excerpts, summaries, or compilations of confidential information; and (3) any testimony, conversations, or presentations by parties or their counsel that might reveal confidential information. However, the protections conferred by this ...


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