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Fox v. Loancare LLC

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

July 24, 2019

SHIRLEY FOX, individually and on behalf of all others similarly situated, Plaintiff,
v.
LOANCARE, LLC, a Virginia limited liability company Defendant.

          STIPULATED PROTECTIVE ORDER

          Marsha J. Pechman United States Senior District Judge

         The Honorable Marsha J. Pechman Plaintiff Shirley Fox and Defendant LoanCare, LLC (the “Parties”) submit the following Stipulated Protective Order.

         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 includes, but is not limited to, the following documents and tangible things produced or otherwise exchanged: (a) documents containing personal identifying information of LoanCare customers; (b) loan or account information relating to LoanCare customers, including data relating to telephone calls made to LoanCare customers; (c) manuals and related documents concerning the telephone system used by LoanCare; and (d) LoanCare's internal policies and procedures and other confidential or proprietary documents.

         “Confidential Purported Class Material” includes, but is not limited to, any documents, data, or information submitted, either voluntarily or pursuant to any subsequent order, regarding putative class members.

         Confidential Purported Class Material is a subset of Confidential material. Confidential Purported Class Material shall be subject to the same protections that exist in this Order for Confidential material, except that Confidential Purported Class Material carries with it the additional restriction that neither Plaintiff nor her counsel may use Confidential Purported Class Material to solicit any clients or class representatives.

         The Parties agree on the following regarding communications with putative class members, if any:

         a. If Plaintiff or her counsel should contact any putative class members regarding this action, Plaintiff's counsel shall notify LoanCare's counsel of the individual contacted within five (5) days of the contact; and

         b. On any call with putative class members, Plaintiff or her counsel shall not make any statements encouraging that individual to opt-out of any purported class or encouraging that individual to bring a separate claim against LoanCare.

         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.

         Confidential material and all information derived therefrom (including but not limited to all testimony, deposition or otherwise, that refers, reflects or otherwise discusses any Confidential material), shall not be used for any purpose whatsoever other than solely in this action and/or for the preparation and trial of this action in accordance with this Order. 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” ...


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