Sinclair et al v. Grandview, City of et al, No. 2:2012cv03041 - Document 229 (E.D. Wash. 2014)
Court Description: ORDER GRANTING STIPULATED MOTION FOR PROTECTIVE ORDER; granting 222 Motion for Protective Order. Signed by Chief Judge Rosanna Malouf Peterson. (LE, Case Administrator)
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Sinclair et al v. Grandview, City of et al Doc. 229 1 2 3 4 5 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WASHINGTON 6 7 8 KAREN SINCLAIR, individually, and as Guardian Ad Litem for KS and JA, minor children, et al., Plaintiffs, 9 NO: 1:12-CV-3041-RMP ORDER GRANTING STIPULATED MOTION FOR PROTECTIVE ORDER v. 10 11 DETECTIVE MICHAEL AKINS, member of the Grandview Police Department, et al., 12 Defendants. 13 14 On February 7, 2014, Plaintiffs and Defendants, Michael Akins and Mark 15 Negrete, by and through their attorneys, agreed and stipulated pursuant to FRCP 16 29, to a protective order regarding certain “Protected Documents.” Having 17 reviewed the file and record and being fully informed, the Court hereby finds good 18 cause to grant the Stipulated Motion and enter the Protective Order. 19 ACCORDINGLY, IT IS HEREBY ORDERED: 20 1. The parties’ Stipulated Motion, ECF No. 222, is GRANTED. ORDER GRANTING STIPULATED MOTION FOR PROTECTIVE ORDER ~ 1 Dockets.Justia.com 1 2. Plaintiffs’ attorneys will not disclose or share any part of the 2 “Protected Documents” described below or any information gleaned from said 3 documents with any person, except as expressly provided herein. 4 5 3. the court are described as follows: 6 7 a. Defendants’ federal income tax returns, including all schedules, attachments, and worksheets; 8 9 The Protected Documents covered by the Stipulation and this Order of b. Statements and other documents relating to defendants’ investments of any kind, including but not limited to securities, stock certificates, 10 bonds, notes, contracts, options, mutual funds, certificates of deposit, Treasury 11 bills, REITS (Real Estate Investment Trusts), tax credits, derivatives and any other 12 investment; 13 14 15 16 c. Documents relating to ownership or other interest in real estate, including but not limited to deeds, settlement statements and appraisals; d. Life insurance policies and other related documents showing value and any loans against those policies; 17 e. Documents relating to any type of annuity; 18 f. Documents describing benefits of employment, including but 19 not limited to statements of benefits and accrued benefits, per diems, expense 20 ORDER GRANTING STIPULATED MOTION FOR PROTECTIVE ORDER ~ 2 1 reimbursements, use of employer vehicles, health and other insurance policies, 2 bonuses, employee incentive plans, etc… 3 4 g. distributions from trusts; 5 6 Trusts and documents showing contributions made to or h. Documents relating to the finances of any business in which defendants have any ownership interest; 7 i. Statements and other documents relating to accounts in which 8 defendants have an interest with a bank, credit union, savings or mutual bank, 9 mutual fund, securities dealer, and brokerage firm; and 10 11 j. 4. Documents reflecting any debts which defendants owe. Plaintiffs’ attorneys agree that prior to any disclosure of Protected 12 Documents as described in this Stipulation and the subsequent Order, they will 13 obtain from each proposed recipient of the Protected Documents their signature on 14 a copy of the Protective Order that states that the recipient has received a copy of 15 the Protective Order regarding the Protected Documents and agrees to be bound by 16 such order. By signing a copy of the Protective Order the recipient agrees that he 17 or she has read the order, represents that he or she is a person permitted to have 18 access to information from the Protected Documents and agrees that he or she will 19 make no further disclosure of the information received, will personally protect the 20 confidentiality of all copies and will either return them to Plaintiffs’ attorneys at ORDER GRANTING STIPULATED MOTION FOR PROTECTIVE ORDER ~ 3 1 the conclusion of this case, or will at that time personally destroy them and upon 2 request from Defendants will provide a sworn affidavit that he or she has done so. 3 5. Subject to the terms of this Stipulation and subsequent Order, 4 Plaintiffs’ attorneys may allow inspection of Protected Documents or discuss the 5 contents of Protected Documents or information therefrom with the following 6 categories of persons and no other: 7 a. 8 Plaintiffs’ attorneys’ office; 9 b. 10 c. 15 Any court personnel, court reporter, mediator, judge and or jury d. Any person identified as having authored or previously in this case; 13 14 Experts, consultants or investigators retained by Plaintiffs’ attorneys to assist in evaluation, preparation or testimony in this case; 11 12 The attorneys and members of the legal and support staff of received the material. 6. Plaintiffs’ counsel shall not allow plaintiffs, their family members or 16 friends to inspect the Protected Documents or discuss the contents of the Protected 17 Documents or information therefrom with those individuals. 18 7. If it becomes necessary for either party to submit a Protected 19 Document to the court, that party shall inform opposing counsel with sufficient 20 time prior to the filing of the Protected Document such that opposing counsel can ORDER GRANTING STIPULATED MOTION FOR PROTECTIVE ORDER ~ 4 1 note a motion to seal the Protected Document. A motion to seal will not be granted 2 unless the motion and supporting documents establish compelling reasons to seal. 3 4 8. The Plaintiffs’ attorneys agree to use the Protected Documents or information obtained from them only for the purpose of prosecuting this litigation. 5 9. At the time of exchange of amended exhibit lists, the Plaintiffs shall 6 list in the amended exhibit list for their case in chief any Protected Document they 7 intend to use at the time of trial by designating the exhibit as a “PROTECTED 8 DOCUMENT” in capital letters. The Defendants may request an in camera review 9 of the exhibit and make the appropriate motion for the handling of the document at 10 trial in accordance with the Jury Trial Scheduling Order. 11 10. Nothing in the Protective Order shall limit any producing party’s use 12 of its own documents or shall prevent any producing party from disclosing its 13 confidential information to any person. 14 11. The court retains jurisdiction to make any amendments, modifications 15 or additions to the Protective Order as it deems appropriate. 16 / / / 17 / / / 18 / / / 19 / / / 20 / / / ORDER GRANTING STIPULATED MOTION FOR PROTECTIVE ORDER ~ 5 1 2 3 4 12. The parties, by stipulation, may add additional documents to be covered by the Stipulation and subsequent Order signed by the court. The District Court Clerk is directed to enter this Order and provide copies to counsel. DATED this 28th day of February 2014. 5 6 7 s/ Rosanna Malouf Peterson ROSANNA MALOUF PETERSON Chief United States District Court Judge 8 9 10 11 12 13 14 15 16 17 18 19 20 ORDER GRANTING STIPULATED MOTION FOR PROTECTIVE ORDER ~ 6
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