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RJB Wholesale, Inc. v. Castleberry

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

March 24, 2017

RJB WHOLESALE, INC., a Washington corporation, Plaintiff,
v.
JEFFREY CASTLEBERRY and JANE DOE CASTLEBERRY, husband and wife and their marital community, Defendants.

          INSLEE, BEST, DOEZIE & RYDER, P.S., Richard A. Bersin, Attorneys for Plaintiff

          STOEL RIVES, LLP, Karin D. Jones, Joseph M. Home, Attorneys for Defendant

          STIPULATION AND PROTECTIVE ORDER [PROPOSED]

          ROBERT S. LASNIKJUDGE

         STIPULATION

         Plaintiff RJB Wholesale, Inc. ("RJB") and defendant Jeffrey Castleberry ("Castleberry"), by and through their counsel of record, stipulate and agree as follows:

         1. Purpose of Stipulation. All parties hereto are interested in permitting discovery to proceed without delay occasioned by possible disputes regarding the confidential nature of certain information. It is anticipated that the parties will request or file pleadings, documents, and information that may be confidential or proprietary in nature. This Stipulation and Protective Order ("Protective Order" or "Order") is intended to protect the confidentiality of such pleadings, documents and information, while ensuring that the parties can pursue litigation and discovery, with a minimum amount of burden, expense and delay. Because RJB and Castleberry's current employer, North American Pipe & Steel Corp. ("NAPSteel"), may, at times, be competitors, this Order is necessary to ensure that their respective confidential business information is protected from misuse for anticompetitive purposes. Additionally, the claims at issue in this litigation involve allegations related to misappropriation of trade secrets. As such, the parties anticipate that significant amounts of confidential business information will be exchanged in discovery. Therefore, this Order is warranted to protect such information from any public disclosure that may harm RJB's, Castleberry's, and/or NAPSteel's business interests.

         2. Protected Material. In the event a party determines in good faith that a document, pleading or other information responsive to a request for discovery is confidential or proprietary and entitled to special protection, that party may invoke this Protective Order and in good faith designate such documents, pleadings or other information as "Protected Material" in the manner set forth below. For purposes of this Order, "Protected Material" is defined as any of the following materials, not publicly available, belonging to RJB, Castleberry, or NAPSteel:

(a) Customer lists and customer contact information;
(b) Customer contracts, invoices, purchase orders, and sales;
(c) Bids, quotes, and estimates;
(d) Product specifications, designs, schematics, and plans;
(e) Sales pitch documents and presentations;
(f) Supplier lists and supplier contact ...

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