United States District Court, W.D. Washington, Seattle
ALBERT VIESSE, on behalf of himself and all others similarly situated, Plaintiff,
TACOMA SCREW PRODUCTS, INC., et al., Defendants.
Yedalian, Admitted Attorneys for Plaintiff
Stephanie Bloomfield, Attorneys for Defendant
STIPULATED PROTECTIVE ORDER
C. COUGHENOUR 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: Various price
information and agreements designated by third parties as
confidential or documents containing sensitive, financial or
confidential information about third parties or parties.
Screw Products proprietary and confidential business
information that is “Confidential”, includes, but
is not limited to:
and Credit/Debit Information;
Names and related Customer Data/Information;
proprietary or confidential business data.
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 ...