United States District Court, W.D. Washington
ADAMA JAMMEH and OUMIE SALLAH, on behalf of themselves and other similarly situated, Plaintiffs,
HNN ASSOCIATES, LLC, GATEWAY, LLC and COLUMBIA DEBT RECOVERY, LLC, d/b/a GENESIS CREDIT MANAGEMENT, LLC, and WILLIAM WOJDAK Defendants.
TERRELL MARSHALL LAW GROUP By: Beth E. Terrell, WSBA #26759
Ari Y. Brown, WSBA #29570 Blythe H. Chandler, WSBA #43387
Brittany J. Glass, WSBA #52095 Sam Leonard, WSBA #46498
LEONARD LAW Paul Arons, WSBA #47599 LAW OFFICE OF PAUL ARONS
Attorneys for Plaintiffs
SMART P.S., INC. By: Jeffrey P. Downer, WSBA #12625 Daniel C.
Mooney, WSBA #44521 Attorneys for Defendants
STIPULATED PROTECTIVE ORDER
HONORABLE JAMES L. ROBART, UNITED STATES DISTRICT COURT 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: (1) personally
identifying information; (2) Plaintiffs' contact
information, including Plaintiffs' telephone numbers,
current addresses, and any of Plaintiffs' prior addresses
other than the rental unit Plaintiffs leased at the Gateway
Apartments; (3) private tenant and/or debtor information,
including credit reports or status, and account status,
payments, or balances; (4) Defendants' respective
policies and procedures, and non-public business or financial
records, which are proprietary and confidential, as
contemplated by Fed.R.Civ.P. 26(c)(1)(G); (5) Defendants'
respective records that identify non-parties and their
personal information; and (6) software used by Defendants in
their business activities.
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 Stipulation and Order do
not cover the following information: any information that is
in the public domain at the time of disclosure to a Receiving
Party or becomes part of the public domain after its
disclosure to a Receiving Party as a result of publication
not involving a violation of this Order, including becoming
part of the public record through trial or otherwise. Any use
of Protected Material at trial shall be governed by a
separate agreement or order.
ACCESS TO AND USE OF CONFIDENTIAL MATERIAL
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.
Disclosure of "CONFIDENTIAL" Information or
otherwise ordered by the court or permitted in writing by the
designating party, a receiving party may disclose any
confidential material only to:
(a) the receiving party's counsel of record in this
action, as well as employees of counsel to whom it is
reasonably necessary to disclose the information for this
(b) the officers, directors, and employees (including in
house counsel) of the receiving party to whom disclosure is
reasonably necessary for this litigation, unless the parties
agree that a particular document or material produced is for
Attorney's Eyes Only and is so designated;
(c) experts and consultants to whom disclosure is reasonably
necessary for this litigation and who have signed the
"Acknowledgment and Agreement to ...