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Diversified Lenders, LLC v. Amazon Logistics, Inc.

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

January 25, 2017

Diversified Lenders, LLC, an Oklahoma limited liability company, Plaintiff,
v.
Amazon Logistics, Inc., a Delaware corporation; Vertical Holdings Unlimited, LLC, a Florida limited liability company doing business as VHU Express, Defendants. Amazon Logistics, Inc., Cross-Claim Plaintiff,
v.
Vertical Holdings Unlimited, LLC, Cross-Claim Defendant.

          Michael W. Ullman Jocelyne A. Macelloni Jared A. Ullman Ullman & Ullman, P.A. Attorneys for Plaintiff, pro hac vice

          Vanessa S. Power (WSBA No. 30777) Reed W. Morgan, pro hac vice STOEL RTVES LLP Attorneys for Defendant Amazon Logistics, Inc.

          STIPULATED PROTECTIVE ORDER

          Robert S. Lasnik United States District Judge

         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, Plaintiff Diversified Lenders, LLC ("Diversified") and Defendant Amazon Logistics, Inc. ("Amazon") (each a "Party" and collectively, the "Parties") hereby stipulate to and petition the court to enter the following Stipulated Protective Order. The Parties acknowledge that this Stipulated Protective Order 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: documents or things constituting or containing either Party's trade secrets, confidential information, financial information, proprietary information, and/or personal information of either Party or its agents or employees.

         3. SCOPE

         The protections conferred by this Stipulated Protective Order 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 Stipulated Protective Order 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 CONFIDENTIAL MATERIAL

         4.1 Basic Principles. A receiving party may use confidential material that is disclosed or produced by another party or by a non-party in connection with this case only for prosecuting, defending, or attempting to settle this litigation. Confidential material may be disclosed only to the categories of persons and under the conditions described in this Stipulated Protective Order. Confidential material must be stored and maintained by a receiving party at a location and in a secure manner that ensures that access is limited to the persons authorized under this Stipulated Protective Order.

         4.2 Disclosure of “CONFIDENTIAL" Information or Items. Unless otherwise .. ordered by the court or permitted in writing by the designating party, a receiving party may disclose any confidential material only to:

(a) the receiving party's counsel of record in this action, as well as employees of counsel to whom it is reasonably necessary to disclose the information for this litigation;
(b) the officers, directors, and employees (including in house counsel) of the receiving party to whom disclosure is reasonably necessary for tins litigation, unless the Parties agree mat a particular document or material produced is for Attorney's Eyes Only and is so designated;
(c) experts and consultants to whom disclosure is reasonably necessary for mis litigation and who have signed the "Acknowledgment and Agreement to ...

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