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Estate of Peters v. Snohomish County

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

October 7, 2019

ESTATE OF NICKOLAS MICHAEL PETERS, by the Personal Representative CARL MICHAEL PETERS; and JAYNI MARIE PETERS and CARL MICHAEL PETERS, individually and their marital community, Plaintiffs,
v.
SNOHOMISH COUNTY as a sub-division of the STATE of WASHINGTON; SNOHOMISH COUNTY DEPUTY SHERIFF ARTHUR J. WALLIN; and CERTAIN UNKNOWN SNOHOMISH COUNTY DEPUTY SHERIFFS JOHN & JANE DOES 1 - 3, Defendants.

          Philip G. Arnold, Campiche Arnold, PLLC Attorneys for Plaintiffs Peters

          Bridget E. Casey, Joseph B. Genster, Katherine H. Bosch, Attorneys for Def. Snohomish County

          Shannon M. Ragonesi Keating Bucklin & McCormack, Inc., PS Attorneys for Defendant Deputy Wallin

          STIPULATED PROTECTIVE ORDER

          Thomas S. Zilly United States District Judge

         Plaintiffs and Defendants to this action (Parties), stipulate to and ask the Court to enter the following Protective Order, which shall apply to documents and information produced or disclosed by the parties pursuant to discovery in this case:

         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 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:

NICKOLAS MICHAEL PETERS

         A. medical records; and B. psychological records.

DEFENDANT DEPUTY WALLIN

         A.

DEFENDANT SNOHOMISH COUNTY

         A. Snohomish County Sheriff's Office employee or personnel records; records of this nature may contain medical or psychological records, home addresses, personal telephone numbers, social security information, date of birth or other personal information.

         B. Snohomish County Sheriff's Office reports of investigation of unrelated incidents that may have relevance to the claims or defenses in this matter. Reports of this nature may contain home addresses, personal telephone numbers, social security information, date of birth or other personal information of civilian witnesses.

         C. Ongoing investigation files; files of this nature may contain confidential medical records or may not yet be complete. .

         D. Any other information to be requested in discovery that has an equivalent need for protection from disclosure as ...


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