Page 1 – STIPULATED PROTECTIVE ORDER

Bruno J. Jagelski, OSB #903049 

bjagelski@yturrirose.com

YTURRI ROSE LLP 

89 SW Third Avenue 

P.O. Box “S” 

Ontario, Oregon 97914 

Telephone: (541) 889-5368 

Facsimile: (541) 889-2432 

 Of Attorneys for Defendants 

 UNITED STATES DISTRICT COURT 

 DISTRICT OF OREGON 

PENDLETON DIVISION 

DOUGLAS WILLIAMS, 

 Plaintiff, 

v. 

GRANT COUNTY, et al., 

 Defendants. 

 

 Case No. 2:15-cv-01760-SU 

STIPULATED PROTECTIVE ORDER 

 The parties to this action stipulate and agree that the 

production of information between them contains confidential and 

personal information subject to protection against unrestricted 

disclosure and use. Based upon the stipulation of the parties, 

and the Court being duly advised, 

IT IS HEREBY ORDERED as follows. 

1. All documents, testimony, and other materials produced 

by the parties in this case and labeled “Confidential” or 

“Attorneys’ Eyes Only” shall be used only in this proceeding. 

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2. Use of any information or documents labeled 

“Confidential” or “Attorneys’ Eyes Only” and subject to this 

Protective Order, including all information derived therefrom, 

shall be restricted solely to the litigation of this case and 

shall not be used by any party for any other purpose. This 

Protective Order, however, does not restrict the disclosure or 

use of any information or documents lawfully obtained by the 

receiving party through means or sources outside of this 

litigation. Should a dispute arise as to any specific 

information or document, the burden shall be on the party 

claiming that such information or document was lawfully obtained 

through means and sources outside of this litigation. 

3. The parties, and third parties subpoenaed by one of 

the parties, may designate as “Confidential” or “Attorneys’ Eyes 

Only” documents, testimony, written responses, or other 

materials produced in this case if they contain information that 

the producing party has a good faith basis for asserting is 

confidential under the applicable legal standards. The party 

shall designate each page of the document with a stamp 

identifying it as “Confidential” or “Attorneys’ Eyes Only,” if 

practical to do so. 

4. If portions of documents or other materials deemed 

“Confidential” or “Attorneys’ Eyes Only” or any papers 

containing or making reference to such materials are filed with 

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the Court, they shall be filed under seal and marked as follows 

or in substantially similar form: 

CONFIDENTIAL or ATTORNEYS’ EYES ONLY 

IN ACCORDANACE WITH A PROTECTIVE ORDER, THE 

ENCLOSURE(S) SHALL BE TREATED AS CONFIDENTIAL AND 

SHALL NOT BE SHOWN TO ANY PERSON OTHER THAN THOSE 

PERSONS DESIGNATED IN PARAGRAPH 6 OF THE 

PROTECTIVE ORDER. 

5. “Confidential” or “Attorneys’ Eyes Only” information 

and documents subject to this Protective Order shall not be 

filed with the Court or included in whole or in port in 

pleadings, motions, briefs, etc., filed in this case, except 

when any portion(s) of such pleadings, motions, briefs, etc., 

have been filed under seal by counsel and marked in the same 

manner as described in paragraph 4 above. Such sealed 

portion(s) of pleadings, motions, briefs, documents, etc., shall 

be opened only by the Court or by personnel authorized to do so 

by the Court. 

6. Use of any information, documents, or portions of 

documents marked “Confidential” or “Attorneys’ Eyes Only,” 

including all information derived therefrom, shall be restricted 

solely to the parties, their attorneys and expert witnesses, all 

of whom agree to be bound by the terms of this Protective Order, 

unless additional persons are stipulated by counsel or 

authorized by the Court. 

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Page 4 – STIPULATED PROTECTIVE ORDER

7. The inadvertent failure to designate a document, 

testimony, or other material as “Confidential” or “Attorneys’ 

Eyes Only” prior to disclosure shall not operate as a waiver of 

the party’s right to later designate the document, testimony, or 

other material as “Confidential” or “Attorneys’ Eyes Only.” 

8. Upon the request of the producing party or third 

party, within 30 days after the entry of a final judgment no 

longer subject to appeal on the merits of this case, or the 

execution of any agreement between the parties to resolve 

amicably and settle this case, the parties and any person 

authorized by this Protective Order to receive confidential 

information shall return to the producing party or third party, 

or destroy, all information and documents subject to this 

Protective Order. Returned materials shall be delivered in 

sealed envelopes marked “Confidential” to respective counsel. 

9. This Protective Order shall not constitute a waiver of 

any party’s or non-party’s right to oppose any discovery request 

or object to the admissibility of any document, testimony or 

other information. 

10. Nothing in this Protective Order shall prejudice any 

party from seeking amendments to expand or restrict the rights 

of access to and use of confidential information, or other 

modifications, subject to order by the Court. 

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The restrictions on disclosure and use of confidential 

information shall survive the conclusion of this action and this 

Court shall retain jurisdiction of this action after its 

conclusion for the purpose of enforcing the terms of this 

Protective Order. 

 SO STIPULATED this 19th day of January, 2016. 

/s/ Lynn S. Walsh /s/ Bruno J. Jagelski 

Lynn S. Walsh, OSB #924955 Bruno J. Jagelski, OSB #903049 

Attorney for Plaintiff Attorney for Defendants 

209 SW Oak Street, Suite 400 Yturri Rose LLP 

Portland, Oregon 97204 P.O. Box “S” 

 Ontario, Oregon 97914 

__________________________________________ 

 The Court, having reviewed the Stipulation of the parties, 

finds that there is good cause to protect the confidential 

nature of certain information. Accordingly, the Court adopts 

the above Stipulated Protective Order in this action. 

IT IS SO ORDERED.

DATED this _____ day of ______________________, 2016. 

 

THE HONORABLE PATRICIA SULLIVAN 

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