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Hussein v. ABM Industries, Inc.

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

April 18, 2017

MOHAMED A. HUSSEIN, an individual, and HASSAN HIRSI, an individual, Plaintiffs,
v.
ABM INDUSTRIES, INC., a foreign corporation, ABM FACILITY SERVICES, INC., a foreign corporation, and AIR SERV CORPORATION, a foreign corporation, Defendants.

          Hearing Dated: April 6, 2017

          SEBRIS BUSTO JAMES Darren A. Feider, WSBA #22430 Jeffrey A. James, WSBA #18277 Attorneys for Defendants.

          BADGLEY MULLINS TURNER PLLC Duncan Turner, WSBA #20597 Attorneys for Plaintiffs.

          LAW OFFICE OF DANIEL R. WHITMORE Daniel R. Whitmore, WSBA #24012 Attorney for Plaintiffs.

          STIPULATED PROTECTIVE ORDER

          THE HONORABLE ROBERT S. LASNIK JUDGE.

         Plaintiffs and defendants through their respective counsel jointly move the Court to enter the following Protective Order regarding Confidentiality pursuant to Federal Rule of Civil Procedure ("FRCP") 26(c).

         1. PURPOSES AND LIMITATIONS

         Discovery in this action is likely to involve production of trade secret, confidential, proprietary, commercially valuable or private information for which special protection may be warranted. Disclosure of such confidential information may cause financial or competitive harm to one or both Parties. 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.

         2. DESIGNATED MATERIALS

         Designated Materials shall include the documents, tangible items, or testimony produced, elicited, or otherwise exchanged in this action which the party producing, disclosing or receiving such materials (the "Designating Party") designates as "Confidential" or "Highly Confidential -Attorneys' Eyes Only." Designated Materials include, but are not limited to, names and contact information of customers, partners and employees; contracts and agreements with customers, partners and employees; information maintained as confidential during the normal course of business related to pricing, revenue, strategy and other commercial interests; and research and development related to content distribution.

         2.1 Designated Materials marked "Confidential" shall include any document, file, portion of file, transcribed testimony or other material that the Designating Party in good faith reasonably believes comprise confidential information related to customers, partners, employees, research, development, and commercial interests.

         2.2 Designated Materials marked as "Highly Confidential - Attorneys' Eyes Only" shall include any document, file, portion of file, transcribed testimony or other material that the Designating Party in good faith reasonably believes comprises trade secrets or other competitive sensitive confidential information, research, development, financial or other commercial information that requires heightened protection. Designated Materials may be designated "Highly Confidential - Attorneys' Eyes Only" only if the Designating Party believes in good faith that designation as "Confidential" will not provide adequate protection.

         3. SCOPE

         The protections conferred by this Order cover not only Designated Materials (as defined above), but also (1) any information copied or extracted from Designated Materials; (2) all copies, excerpts, summaries, or compilations of Designated Materials; and (3) any testimony, conversations, or presentations by Parties or their counsel that might reveal Designated Materials. However, the protections conferred by this 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 DESIGNATED MATERIALS

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

         4.2 Disclosure of "Confidential" Information or Items. Unless otherwise ordered by the Court or permitted in writing by the Designating Party, material designated as "Confidential" may be disclosed only to the following persons:

(a) the receiving party;
(b) 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;
(c) the officers, directors, and employees (including in house counsel) of the receiving party to whom disclosure is ...

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