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Dunlap v. King County

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

December 10, 2019

ALEXIS DUNLAP, individually and as the personal representative of the estate of MiChance Dunlap-Gittens, and FRANK GITTENS, Plaintiffs,
v.
KING COUNTY et al. Defendants.

          PATRICIA BOSMANS, WSBA #9148 Attorney for Alexis Dunlap and the Estate of MiChance Dunlap-Gittens

          TIFFANY CARTWRIGHT, WSBA #43564 TIMOTHY K. FORD, WSBA #5986Attorneys for Alexis Dunlap and the Estate of MiChance Dunlap-Gittens

          DAVID B. OWENS, WSBA #53856 Attorney for Alexis Dunlap and the Estate of MiChance Dunlap-Gittens

          JAMES BIBLE, WSBA #33985 Attorney for Plaintiff Frank Gittens

          ENDEL KOLDE, WSBA #25155 AMY E. MONTGOMERY, WSBA #32068 Attorneys for King County Defendants

          ORDER

          JOHN C. COUGHENOUR, UNITED STATES DISTRICT JUDGE

         This matter comes before the Court on the parties' stipulated motion for entry of a protective order (Dkt. No. 20). The Court hereby GRANTS the motion and ENTERS the following:

         1. PURPOSES AND LIMITATIONS

         Discovery in this action is likely to involve production of confidential, statutorily protected, or private information, or other material which is exempt from public disclosure or for which special protection may be warranted. This agreement is consistent with Western District of Washington Local Civil Rule 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, electronically stored information (ESI) and tangible things produced or otherwise exchanged:

a. Non-public records such as King County employee personnel files, including performance evaluations protected Wash. Rev. Code § 42.56.210;
b. Non-public records such as King County employee employment applications, protected by Wash. Rev. Code § 42.56.250;
c. Any other information normally exempt from public disclosure that is relevant to this case (such as personnel records and records containing protected personal information);
d. The medical records of the deceased, MiChance Dunlap-Gittens;
e. Juvenile prosecution records, except for information in the publicly available court record;
f. The names of juveniles as recorded in police reports related to this litigation, except for the name of the deceased, MiChance Dunlap-Gittens, and
g. Any other material that enjoys special legal protection from disclosure and that is relevant to the claims or defenses in this case.

         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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