United States District Court, E.D. Washington
STIPULATED PROTECTIVE ORDER
SALVADOR MENDOZA, JR. United States District Judge.
the Court, without oral argument, is the parties'
Stipulated Motion for a Protective Order. ECF No. 16. Having
reviewed the pleadings and file in this matter, the Court is
fully informed and GRANTS the motion. Pursuant to FRCP 26(c)
and the stipulation of the parties, the Court hereby enters
the following Protective Order:
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
have stipulated to the following Stipulated Protective Order.
ECF No. 16. This Order 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:
• Tax Returns;
• Business Models;
• Rate and Pricing Information;
• Customer or Marketing Information;
• Confidential Commercial Information; and
• Proprietary Information.
protections conferred by this Order 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 Order do not cover information that is in
the public domain or becomes part of the public domain
through trial or otherwise.
ACCESS TO AND USE OF CONFIDENTIAL MATERIAL
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 Order. Confidential material must be stored and
maintained by a receiving ...