United States District Court, W.D. Washington, Seattle
Sanders William K. Miller Perkins Coie LLP Attorneys for
Defendant City of Everett
G. Jarrard Law Office of Thomas G. Jarrard, PLLC Matthew Z.
Crotty, Attorneys for Plaintiffs
STIPULATED PROTECTIVE ORDER
S. Zilly United States District Judge.
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:
• Employee and personnel files of non-parties;
• Law enforcement records containing personal
information of non-parties or other law enforcement
information treated as confidential by the City;
• Emails and other communications which contain
confidential personal information about law enforcement
• Military records of non-parties;
• Medical records of any person; and
• Any other records containing information exempt from
disclosure under the Washington Public Records Act.
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 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.
ACCESS TO AND USE OF ...