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Doe v. BHC Fairfax Hospital, Inc.

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

October 23, 2019

JANE DOE, JOHN DOE, AND H.S. by and through his guardian, individually and on behalf of all others similarly situated, Plaintiffs,
v.
BHC FAIRFAX HOSPITAL, INC. d/b/a FAIRFAX BEHAVIORAL HEALTH, Defendant.

          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. The parties to this action stipulate that the following Protective Order apply to documents and information produced or disclosed in this case:

         2. “CONFIDENTIAL” MATERIAL

         “Confidential” material shall include the following documents and tangible things produced or otherwise exchanged:

A) Social security numbers (5 U.S.C. § 552a(b)); LCR 5.2a(3).
B) Personal information in files maintained for clients of public institutions or welfare recipients (42 U.S.C. § 671(a)(8); Wash. Rev. Code 42.56.230(1); Wash. Rev Code 74.04.060);
C) Health care information (Wash. Rev. Code 70.02.010(16));
D) Records related to mental illness and treatment (Wash. Rev. Code 71.05.390; Wash. Rev. Code 71.34.340);
E) Credit card numbers, debit card numbers, electronic check numbers, card expiration date, bank, or other financial account numbers (LCR 5.2(a)(4));
F) Documents containing information regarding the identity of persons making reports regarding vulnerable adults, and all files, reports, records, communications, and working papers used or developed in the investigation or provision of protective services is subject to protection under state law (Wash. Rev. Code 74.34.095);
G) Other material protected by federal or state statute or regulation or court rule including, without limitation, patient safety work-product under the Patient Safety and Quality Improvement Act, 42 U.S.C. § 299b-21 et. seq., 42 C.F.R. 3.204 .

         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 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 may ...


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