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Providence Health & Services v. Certain Underwriters at Lloyd's London

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

August 7, 2019

PROVIDENCE HEALTH AND SERVICES; and SWEDISH HEALTH SERVICES, Plaintiffs,
v.
CERTAIN UNDERWRITERS AT LLOYD'S LONDON, SYNDICATE 2623/623 BEAZLEY; and FEDERAL INSURANCE COMPANY, Defendants.

          GORDON TILDEN THOMAS & CORDELL LLP Attorneys for Plaintiffs Franklin D. Cordell, WSBA #26392 Brendan Winslow-Nason, WSBA #39328 Chelsey L. Mam, WSBA #44609

          WILSON SMITH COCHRAN DICKERSON Attorneys for Defendants Certain Underwriters at Lloyd's London, Syndicate 2623/623 (Beazley) John M. Silk, WSBA #15035

          TROUTMAN SANDERS Attorneys for Defendants Certain Underwriters at Lloyd's London, Syndicate 2623/623 (Beazley) Kevin F. Kieffer Monique F. Fuentes Ross Smith

          SOHA & LANG, PS Attorneys for Defendant Federal Insurance Company Steven Soha, WSBA #09415 Geoffrey Bedell, WSBA #28837

          STIPULATED PROTECTIVE ORDER

          RICARDO S. MARTINEZ CHIEF UNITED STATES DISTRICT JUDGE.

         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, Plaintiffs Providence Health and Services and Swedish Health Services (“Providence”) and Defendants Certain Underwriters at Lloyd's London, Syndicate 2623/623 (“Beazley”) and Federal Insurance Company (collectively “Insurers”), 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:

• Documents with patient health information that Providence is obligated to protect under a variety of laws, including but not limited to, the federal Health Insurance Portability and Accountability Act and Washington's Uniform Health Care Information Act.
• Documents that include confidential commercial information, including but not limited to trade secrets, policies regarding proprietary business operations, employment contracts, and business organization charts.

         The parties reserve the right to seek leave for amendment of this order by the Court if additional categories of materials are identified as this matter proceeds

         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. 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 ...


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