R.K. v. Corporation of the President of the Church of Jesus Christ of Latter-Day Saints, et al

Filing 74

R.K. v. Corporation of the President of the Church of Jesus Christ of Latter-Day Saints, et al

Doc. 74

Case 2:04-cv-02338-RSM

Document 74

Filed 01/17/2006

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THE HONORABLE RICARDO MARTINEZ

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON AT SEATTLE KENNETH FLEMING, JOHN DOE, R.K., and T.D., Plaintiffs, v. THE CORPORATION OF THE PRESIDENT OF THE CHURCH OF JESUS CHRIST OF LATTER-DAY SAINTS, a Utah corporation sole, a/d/a "MORMON CHURCH"; LDS SOCIAL SERVICES a/d/a LDA FAMILY SERVICES, a Utah corporation, Defendants. NO. C04-2338 RSM STIPULATION AND PROTECTIVE ORDER

I.

STIPULATION

This Stipulation is entered into by and between Gordon, Thomas, Honeywell, Malanca, Peterson & Daheim LLP, as well as The Law Offices of Timothy D. Kosnoff, on behalf of plaintiffs, and Stafford Frey Cooper on behalf of defendants. The parties stipulate as follows: 1. This Stipulation is intended to specify the handling of all documents and

information that identifies the names of non-party victims of sexually inappropriate conduct
STIPULATION AND PROTECTIVE ORDER - 1 of 3 (C04-2338 RSM) [fleming04-2388PO.doc]

LAW OFFICES

GORDON, THOMAS, HONEYWELL, MALANCA, PETERSON & DAHEIM LLP
ONE UNION SQUARE 600 UNIVERSITY, SUITE 2100 SEATTLE, WASHINGTON 98101-4185 [phone] - FACSIMILE [phone]

Dockets.Justia.com

Case 2:04-cv-02338-RSM

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by Jack LoHolt of whom Philip J. Coleman became aware while he was serving as bishop and/or whose identities were reported to him in his capacity as bishop, excluding any information obtained through communication with Mr. Coleman's attorneys. Neither the attorney-client privilege nor priest-penitent privilege is waived. 2. In any briefing filed with the court by the parties, these non-party victims will

be referred to by initials only. In all other court filings by the parties, the names of these nonparty victims shall be redacted. 3. The disclosure by the counsel for the defendants of the names of these non-

party victims SHALL NOT be deemed a waiver in whole or in part of any defendants' claim of confidentiality and/or privilege, either as to the specific information disclosed or as to any other information relating thereto or on the same or related subject matter. DATED this 12th day of January, 2006. GORDON, THOMAS, HONEYWELL, MALANCA, PETERSON & DAHEIM LLP By: /s/ Michael T. Pfau Michael T. Pfau, WSBA No. 24649 [e-mail] Co-Counsel for Plaintiffs LAW OFFICES OF TIMOTHY D. KOSNOFF By: /s/ Timothy D. Kosnoff Timothy D. Kosnoff, WSBA No. 16586 [e-mail] Co-Counsel for Plaintiffs

STIPULATION AND PROTECTIVE ORDER - 2 of 3 (C04-2338 RSM) [fleming04-2388PO.doc]

LAW OFFICES

GORDON, THOMAS, HONEYWELL, MALANCA, PETERSON & DAHEIM LLP
ONE UNION SQUARE 600 UNIVERSITY, SUITE 2100 SEATTLE, WASHINGTON 98101-4185 [phone] - FACSIMILE [phone]

Case 2:04-cv-02338-RSM

Document 74

Filed 01/17/2006

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STAFFORD FREY COOPER By: /s/ Marcus B. Nash Thomas D. Frey, WSBA No. 1908 Marcus B. Nash, WSBA No. 14471 Counsel for Defendants II. ORDER

Based on the foregoing Stipulation, IT IS SO ORDERED. DATED this 17 day of January, 2006.

A
Presented by: GORDON, THOMAS, HONEYWELL, MALANCA, PETERSON & DAHEIM LLP By: /s/ Michael T. Pfau Michael T. Pfau, WSBA No. 24649 [e-mail] Co-Counsel for Plaintiffs LAW OFFICES OF TIMOTHY D. KOSNOFF By: /s/ Timothy D. Kosnoff Timothy D. Kosnoff, WSBA No. 16586 [e-mail] Co-Counsel for Plaintiffs STAFFORD FREY COOPER By: /s/ Marcus B. Nash Thomas D. Frey, WSBA No. 1908 Marcus B. Nash, WSBA No. 14471 Counsel for Defendants
STIPULATION AND PROTECTIVE ORDER - 3 of 3 (C04-2338 RSM) [fleming04-2388PO.doc]

RICARDO S. MARTINEZ UNITED STATES DISTRICT JUDGE

LAW OFFICES

GORDON, THOMAS, HONEYWELL, MALANCA, PETERSON & DAHEIM LLP
ONE UNION SQUARE 600 UNIVERSITY, SUITE 2100 SEATTLE, WASHINGTON 98101-4185 [phone] - FACSIMILE [phone]