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Gilmore v. Boeing Co.

United States District Court, W.D. Washington, Seattle

January 24, 2017

MICHAEL GILMORE, Plaintiff,
v.
BOEING COMPANY, Defendant.

          REED LONGYEAR MALNATI & AHRENS, PLLC Elizabeth A. Hanley, WSBA # 38233 Reed Longyear Malnati & Ahrens, PLLC Attorney for Plaintiff

          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

          JOHN C. COUGHENOUR UNITED STATES DISTRICT JUDGE

         This matter comes before the Court on the parties' stipulated proposed protective order (Dkt. No. 13). The Court hereby ORDERS the following:

         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:

(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.

         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 agreement do not cover information that is in the public domain or becomes part of the public domain through trial or otherwise.

         4. ACCESS TO AND USE OF ...


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