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Beaming White LLC v. Rabon

United States District Court, W.D. Washington

May 24, 2017

BEAMING WHITE LLC, and LUIS LAJOUS, Plaintiffs,
v.
JASON RABON, SHANON RABON, the marital estate of JASON and SHANON RABON, WHITEN MY SMILE NOW; VISION MARKETING CONSULTANTS, INC., a Delaware corporation; d/b/a ON THE GO WHITENING, WHITEN MY SMILE NOW, and/or DAZZLING WHITE SMILE USA, Defendants.

          Kurt M. Rylander, Mark E. Beatty, RYLANDER & ASSOCIATES PC Attorneys for Plaintiffs

          Sarah E. Nagae, NEXSEN PRUET, PLLC Brian F. McMahon, CHRISTENSEN O'CONNOR JOHNSON KINDNESS PLLC Attorneys for Defendants

          STIPULATED PROTECTIVE ORDER

          David W. Christel United States Magistrate Judge

         Pursuant to Fed.R.Civ.P. 26(c) and the Local Rules, Plaintiffs Beaming White LLC and Luis Lajous, and Defendants Jason Rabon, Shanon Rabon, the marital estate of Jason and Shanon Rabon, Whiten My Smile Now, and Vision Marketing Consultants and dba On the Go Whitening, Whiten My Smile Now and/or Dazzling White Smile USA hereby submit the following Stipulated Protective Order for approval and entry by the Court.

         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 (regardless of how generated, stored, or maintained):

(a) Material the producing party has regarding its customers and its competitors;
(b) Non-public contracts the producing party has with manufacturers, suppliers, vendors, customers, contractors and subcontractors;
(c) The financial books and records of the producing party and financial information pertaining to the financial books and records;
(d) Material about the revenues, costs, expenses, profits, and losses of the producing party;
(e) Personal information of any employee, customer, or other person;
(f) Any material the producing party is obligated by contract or state or federal law to keep confidential;
(g) Any other material which the producing party in good faith reasonably believes to include trade secrets, future development or marketing plans, confidential research, development, commercial, or other sensitive information.

         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 ...


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