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Ridley v. Emagin Corp.

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

March 28, 2017

ROBERT BRUCE RIDLEY, an individuals Plaintiff,
EMAGIN CORPORATION, a Delaware Corporation, Defendant. EMAGIN CORPORATION, a Delaware Corporation Counterclaimant,
ROBERT BRUCE RIDLEY, an individual, Counterdefendant.


          LITTLER MENDELSON, P.C. LITTLER MENDELSON P.C., Attorney for Defendant/Counterclaimant EMAGIN CORPORATION


          Honorable Robert S. Lasnik United States District Judge


         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 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.


          "Confidential" material shall include the following documents and tangible things produced or otherwise exchanged: Defendant's trade secrets, customer lists and/or accounts, product design or development, market share, business development plans, and business forecasts or projections; confidential documents regarding Defendant's recruitment, assessment, evaluation, and/or and training of employees; documents concerning Defendant's finances, income tax returns, revenue, or compensation of employees; documents, data, statistics, and/or personnel information concerning Defendant's employees, former employees, or candidates for employment, including, but not limited to: demographic data, contact information, employment and performance history, personnel records, communications, and/or statistics regarding any and all persons other than Plaintiff. "Confidential" material shall also include plaintiffs sensitive personal, financial, and/or medical records including his tax records, tax schedules, medical records, medical insurance or benefit records, social security number, bank account records, voided checks, financial statements, loan documents, or similar financial records that are not publically available. The parties agree that such information shall remain confidential whether it is found in documents, designated portions of deposition testimony, or responses to interrogatories, requests for admissions, or requests for production of documents.

         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 protection 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.


         4.1 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 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.

         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 this litigation, unless the parties agree that a particular document or material produced is for Attorney's Eyes Only and the document is so designated;
(c) experts and consultants to whom disclosure is reasonably necessary for this litigation and who have signed the "Acknowledgment and Agreement to ...

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