United States District Court, W.D. Washington, Seattle
LONGYEAR MALNATI & AHRENS, PLLC Elizabeth A. Hanley, WSBA
# 38233 Reed Longyear Malnati & Ahrens, PLLC Attorney for
MORGAN, LEWIS, & BOCKIUS, LLP Mr. Clifford D. Sethness,
WSBA# 14110 Ms. Jocelyn R. Cuttino, pro hac vice Morgan,
Lewis, & Bockius, LLP
RIDDELL WILLIAMS, P.S. Mr. Laurence A. Shapero, WSBA # 31301
Riddell Williams, P.S.
STIPULATED PROTECTIVE ORDER
C. COUGHENOUR UNITED STATES DISTRICT JUDGE
matter comes before the Court on the parties' stipulated
proposed protective order (Dkt. No. 13). The Court hereby
ORDERS the following:
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:
(a) Payroll records pertaining to any current or former
employee of Defendant that contains financial account
information. Good cause exists to protect the privacy rights
of Defendant's current and former employees who are not
parties to this litigation. No public interest is served by
requiring public disclosure of an individual's private
and personal financial information in a matter in which he or
she is not a party.
(b) Medical and mental health records pertaining to the
parties, or any non-party, to the extent the information is
discoverable. Good cause exists to protect highly sensitive
and private nature of all medical records from non-party
access. No public interest is served by making any medical
records of Plaintiff or any non-party publicly available.
(c) Financial records of the parties, including tax records.
Good cause exists to protect private financial records from
non-party access. No public interest is served by these
records being publicly available.
(d) Proprietary business information, information regarding
corporate strategy, a trade secret or other commercial or
financial information that would result in competitive or
commercial harm in the marketplace if the material were
disseminated to persons outside The Boeing Company or
reviewed by persons other than those specifically identified
herein for purposes of this litigation.
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 agreement do not cover information that is
in the public domain or becomes part of the public domain
through trial or otherwise.
ACCESS TO AND USE OF ...