United States District Court, W.D. Washington, Seattle
S.B., M.B., J.M. Jr., and G.M., minors, by Bruce A. Wolf, their guardian ad litem, Plaintiffs,
United States of America, Defendant.
M. RESSLER, WSBA #5330 Ressler & Tesh, PLLC Attorney for
W. FERGUSON Attorney General ZEBULAR J. MADISON, WSBA No.
37415 Assistant Attorney General Attorneys for State of
Respectfully submitted, BRIAN T. MORAN United States Attorney
TRICIA BOERGER, WSBA #38581 Assistant United States Attorney
Western District of Washington United States Attorney's
Office Attorneys for the United States
STIPULATED PROTECTIVE ORDER
S. LASNIK UNITED STATES DISTRICT JUDGE.
Honorable Robert S. Lasnik
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:
of Washington Records
DSHS/DCYF MODIS and FamLink files of S.B., M.B., J.M. Jr.,
and G.M., 's biological parents;
Children's Administration / MODIS files of S.B., M.B.,
J.M. Jr., and G.M., minors;
Children's Administration files of N.W., K.M., and S.A.;
Children's Administration files of J.B., C.L., Sa.B.;
Children's Administration files of A.M., J.M., R.M.,
J.R., T.R., G.A., T.E., D.M., and Ja.M.;
Children's Administration files of A.MW., A.W., E.W., and
Children's Administration files of C.C. and D.F.;
Children's Administration files of L.M. and W.M.;
Children's Administration files of M.B., K.S., L.M.S.,
Children's Administration files of G.D., A.I. and K.I.;
files of Muckleshoot Youth Recovery Home, Ryther Child
Center, and Children in the Service Alternatives Cedar House;
Licensing files of various foster parents, containing records
of adults and minors not parties to this case;
Files for foster homes where S.B., M.B., J.M. Jr., and G.M.
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