United States District Court, W.D. Washington, Seattle
Bruce & Willey LLP David N. Bruce, Miles A. Yanick,
Attorneys for Tech Mahindra (Americas), Inc.
Island Law Group, George O. Tambly, Timothy PauleynAttorneys
for Jay Burdette.
STIPULATED MOTION AND PROTECTIVE ORDER
James L. Robart United State 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;
(a) Confidential information relating to the work performed
by Tech Mahindra or its parent, Tech Mahindra Limited, for
AT&T, including but not limited to business plans and any
agreements or statements of work for AT&T;
(b) AT&T financial information;
(c) Confidential technical information or specifications,
scenarios, modelling, and proposals;
(d) Information that the designating party reasonably
believes constitutes, reflects, or discloses trade secrets,
proprietary data, or commercially sensitive information;
(e) Information about employees or contractors that is
treated as confidential by the designating party or by Tech
Mahindra or Tech Mahindra Limited's customers, vendors,
or others with whom it does business;
(f) Information subject to confidentiality agreements with
third parties or preexisting confidentiality agreements
between the parties;
(g) Plaintiffs tax returns and information used in
preparation of those tax returns;
(h) Plaintiff s medical ...