United States District Court, W.D. Washington, Seattle
K. Stahlfeld, WSBA No. 22003 Kellen Andrew Hade, WSBA No.
44535 MILLER NASH GRAHAM & DUNN LLP Attorneys for
Patrick B. Reddy, WSBA No. Amanda V. Masters, WSBA No. EMERY
REDDY, PLLC Attorneys for Plaintiff.
STIPULATED PROTECTIVE ORDER
S. LASNIK UNITED STATES DISTRICT JUDGE.
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: defendants'
customer lists, defendants' business information about
its products, pricing, and productivity metrics and
compensation provided to non-party employees, and plaintiffs
medical records and health information.
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 CONFIDENTIAL MATERIAL.
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 agreement. 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 agreement.
Disclosure of "CONFIDENTIAL" Information or
otherwise ordered by the court or permitted in writing by the
designating party, a receiving party may disclose any
confidential material only to:
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;
officers, directors, and employees (including in house
counsel) of the receiving party to whom disclosure is
reasonably necessary for this litigation, unless the parties
agree that a particular document or material produced is for
Attorney's Eyes Only and is so designated;
experts and consultants to whom disclosure is reasonably
necessary for this litigation and who have signed the
"Acknowledgment and ...