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Burdette v. Tech Mahindra (Americas) Inc.

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

May 3, 2017

JAY BURDETTE, Plaintiff,
v.
TECH MAHINDRA (AMERICAS INC.), Defendant.

          Savitt Bruce & Willey LLP David N. Bruce, Miles A. Yanick, Attorneys for Tech Mahindra (Americas), Inc.

          Mercer Island Law Group, George O. Tambly, Timothy PauleynAttorneys for Jay Burdette.

          STIPULATED MOTION AND PROTECTIVE ORDER

          Hon. James L. Robart United State District Judge.

         1. 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 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 ...

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