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Holmes v. Yct. Nova

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

April 19, 2017

ROBERT HOLMES, a married individual, and MARQUIS INTERNATIONAL HOLDINGS, LLC, a Washington limited liability company, Plaintiffs,
v.
YCT. NOVA WA Registration No. WN9647LK, her engines, tackle, apparel, appurtenances, etc., in rem; YCT. M SQUARED Official No. 1202018, her engines, tackle, apparel appurtenances, etc., in rem; STEPHEN YADVISH, a married individual, and the marital community of Stephen Yadvish and Jodee Frye, in personam; YACHTFISH MARINE, INC., a Washington corporation, in personam; and S. B. JOSEPH CLARK, a married individual, and the marital community of S. B. Joseph Clark and Jane Doe Clark, in personam, Defendants.

          MILLER NASH GRAHAM & DUNN LLP Jess G.Webster, Drew F. Duggan MILLER NASH GRAHAM & DUNN LLP Attorneys for Plaintiffs and Counter-Defendants Robert Holmes Marquis International Holdings

          CARSON & NOEL, PLLC Wright A. Noel, Merryn DeBennedetti CARSON & NOEL, PLLC Attorneys for Defendants Yachtfish Marine, Inc. and Stephen Yadvish

          HOLMES WEDDLE & BARCOTT, P.C. John E. Casperson, Heather C. Cook Attorneys for Defendant S. B. Joseph Clark

          MODEL STIPULATED PROTECTIVE ORDER

          Honorable Robert S. Lasnik United States District Court Judge

         I. PURPOSES AND LIMITATIONS

         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 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. "CONFIDENTIAL" MATERIAL

         "Confidential" material shall include the following documents and tangible things produced or odierwise exchanged:

A. Personal banking and other financial information of the parties.
B. Private business information that would be considered a trade secret.
C. Information otherwise provided protection from disclosure under the law.

         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 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.

         4. ACCESS TO AND USE OF CONFIDENTIAL MATERIAL

         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 m 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 ...


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