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Samson v. UnitedHealthcare Services Inc

United States District Court, W.D. Washington

June 21, 2019

FRANTZ SAMSON, a Washington resident, individually and on behalf of all others similarly-situated, Plaintiff,
v.
UNITEDHEALTHCARE SERVICES, INC., Defendant.

          TERRELL MARSHALL LAW GROUP PLLC JENNIFER RUST MURRAY, BETH E. TERRELL, ADRIENNE D. MCENTEE, JAMES A. FRANCIS, JOHN SOUMILAS, FRANCIS & MAILMAN, P.C., KEVIN LAUKAITIS, AARTHI MANOHAR KOFIN, SWIFT & GRAF, P.C. ATTORNEYS FOR PLAINTIFF

          HOLLAND & KNIGHT LLP SHANNON ARMSTRONG, KRISTIN M. ASAI, NIPUN PATEL, PAUL BOND, HOLLAND & KNIGHT LLP ZALIKA PIERRE, ATTORNEYS FOR DEFENDANT

          STIPULATION AND [PROPOSER] PROTECTIVE ORDER [1]

          HONORABLE JAMES L. ROBART JUDGE

         I. STIPULATION

         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 include the following documents and tangible things produced or otherwise exchanged: (1) personal and private information regarding Plaintiff and proposed class members, including current and former street addresses for natural persons, social security numbers, telephone numbers, email addresses, dates of birth, driver's license numbers, account numbers, maiden names, and passwords; (2) confidential business and financial information; (3) trade secrets or other confidential research, development, or commercial information; and (4) patient health information "PHI") that is protected under the Health Insurance Portability and Accountability Act ("HIPAA"), 45 C.F.R. Parts 160 and 164 (Privacy Rules), or other applicable statute. With respect to any PHI, the producing party may redact any information concerning physical or mental health condition and/or health care, but shall not redact name and contact information (e.g., phone number, e-mail, physical address). To the extent the producing party can produce requested information without also producing irrelevant information concerning physical or mental health condition and/or health care, the producing party will produce the requested information and refrain from producing the irrelevant information. For example, if names and contact information is maintained in a structured database that also houses information regarding physical or mental health, the database should be queried so that the requested names and contacted information are produced and the information regarding physical or mental health is not produced.

         It is the parties' intent that information will not be designated confidential without a good faith belief that it has been maintained in a confidential, non-public manner, and there is good cause why it should not be part of the public record in this case.

         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 (1) information that is in the public domain or becomes part of the public domain through trial or otherwise; (2) any information known to the receiving party prior to the disclosure or obtained by the receiving party after the disclosure from a source who obtained the information lawfully and under no obligation of confidentiality to the designating party; and (3) information regarding or relating to the receiving party.

         Finally, any use of confidential material at trial shall be governed by a separate agreement or order.

         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. It is expressly intended and agreed that Confidential material will not be made public via social media, Internet publication, or otherwise.

         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 parties;
(b) the receiving party's counsel of record in this action, as well as employees of counsel to whom it is reasonably necessary to disclose the information for this litigation;
(c) the officers, directors, and employees (including in-house counsel) of the receiving party to whom disclosure is reasonably necessary for this litigation;
(d) experts and consultants to whom disclosure is reasonably necessary for this litigation and who have signed the "Acknowledgment and Agreement to Be Bound" (Exhibit A); (e) the court, court personnel, and court reporters and their staff, including any court reporter or videographer reporting a deposition;
(f) copy or imaging services retained by counsel to assist in the duplication of confidential material, provided that counsel for the party retaining the copy or imaging service instructs the service not to disclose any confidential material to third parties and to ...

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