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Gailey v. City of Everett

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

August 20, 2019

BRETT GAILEY, Plaintiff,
v.
THE CITY OF EVERETT, Defendant.

          James Sanders William K. Miller Perkins Coie LLP Attorneys for Defendant City of Everett

          Thomas G. Jarrard Law Office of Thomas G. Jarrard, PLLC Matthew Z. Crotty, Attorneys for Plaintiffs

          STIPULATED PROTECTIVE ORDER

          Thomas S. Zilly 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 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:

• 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 employees;
• 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.

         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 ...


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