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Jammeh v. HNN Associates, LLC

United States District Court, W.D. Washington

December 16, 2019

ADAMA JAMMEH and OUMIE SALLAH, on behalf of themselves and other similarly situated, Plaintiffs,
v.
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

          LEE SMART P.S., INC. By: Jeffrey P. Downer, WSBA #12625 Daniel C. Mooney, WSBA #44521 Attorneys for Defendants

          STIPULATED PROTECTIVE ORDER

          THE HONORABLE JAMES L. ROBART, UNITED STATES DISTRICT COURT 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: (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.

         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 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.

         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 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 litigation;
(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 ...

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