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Naini v. King County Hospital District No. 2

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

July 30, 2019

ALI J. NAINI, M.D., Plaintiff,
v.
KING COUNTY HOSPITAL DISTRICT NO. 2, d/b/a EVERGREEN HOSPITAL MEDICAL CENTER, et al., Defendants.

          CORR CRONIN, LLP LAWRENCE R. COCK, STEVEN W. FOGG, EMILY J. HARRIS, EMMA GRUNBERG, BENJAMIN BYERS, ATTORNEYS FOR PLAINTIFF

          LAW OFFICES OF ROBERT N. MEALS SILVER TIP TRAIL BOZEMAN ATTORNEYS FOR PLAINTIFF

          BENNETT BIGELOW & LEEDOM, P.S. BRUCE W. MEGARD, JR., JENNY M. CHURAS, ATTORNEYS FOR DEFENDANTS

          ORDER

          JOHN C. COUGHENOUR UNITED STATES DISTRICT JUDGE.

         This matter comes before the Court on the parties' stipulated protective order (Dkt. No. 26). The Court hereby ENTERS 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 Local Civil Rule 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. This agreement does not alter the parties' obligations and duties under the Health Insurance Portability and Accountability Act of 1996 (HIPAA), 45 C.F.R. § 164.500, et seq. or Washington's Health Care Information Access and Disclosures statutes, Wash. Rev. Code chapter 70.02.

         2. “CONFIDENTIAL” MATERIAL

         “Confidential” material shall include the following documents and tangible things produced or otherwise exchanged: (1) protected health information as defined by 45 C.F.R. § 160.103; (2) competitive compensation information; (3) confidential or proprietary documents regarding corporate development, recruitment, future forecasts or business plans, or decision-making; (4) trade secrets; (5) documents subject to contractual confidentiality provisions; (6) confidential and/or non-public employment records; and (7) competitively sensitive financial records, including, but not limited to tax returns.

         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.

         The protections in this stipulation are available to third parties responding to subpoenas in this proceeding if they have executed the “Acknowledgment and Agreement to Be Bound” (Exhibit A) and provided a copy of the executed “Acknowledgment and Agreement to Be Bound” (Exhibit A), in conjunction with their responsive materials.

         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's ...


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