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Davis v. Johnson International Industries, Inc.

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

June 1, 2017

MICHAEL DAVIS, Plaintiff,
v.
JOHNSON INTERNATIONAL INDUSTRIES, INC., d/b/a CONTINENTAL HARDWOOD CO., a Washington Corporation, and LISA JOHNSON, an individual and the marital community comprised of LISA JOHNSON and DON FULLER, Defendants.

          Todd W. Wyatt, WSBA #31608 Marina M. Visan, WSBA #49127 CARSON & NOEL PLLC Attorneys for Plaintiff

          Darren A. Feider, WSBA #22430 Tina M. Aiken, WSBA # 27792 Attorneys for Defendants

          STIPULATED PROTECTIVE

          Thomas S. Zilly United States District Judge

         Plaintiff Michael Davis and Defendants Johnson International Industries, Inc., d/b/a Continental Hardwood Co., Lisa Johnson and Don Fuller, through their respective counsel of record, hereby move pursuant to Federal Rule of Civil Procedure (26)(c) for entry of this Stipulated Protective Order:

         1. PURPOSES AND LIMITATIONS

         Discovery in this action is likely to involve production of confidential, proprietary, commercially valuable or private information for which special protection may be warranted. Disclosure of such confidential information may cause financial or competitive harm to one or both Parties. Accordingly, the parties hereby stipulate to and petition the court to enter the following Stipulated Protective Order. The parties acknowledge that this Order is consistent Sebris Busto James 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. DESIGNATED MATERIAL

         “Designated Material” shall include the documents, tangible items, or testimony produced, elicited, or otherwise exchanged in this action which the party producing or disclosing such material (the “Designating Party”) designates as “Confidential” or “Highly Confidential - Attorneys' Eyes Only.” Designated Material may include, but is not limited to, names and contact information of customers and employees; contracts and agreements with customers and employees; personnel information related to non-parties; information maintained as confidential during the normal course of business related to sales, pricing, revenue, strategy and other commercial interests; and medical records.

         2.1 Designated Material marked “Confidential” shall include any document, file, portion of file, transcribed testimony or other material that the Designating Party in good faith reasonably believes comprises confidential information related to customers, employees, commercial interests, or other information that could cause commercial, professional, or personal harm through disclosure.

         2.2 Designated Material marked as “Highly Confidential - Attorneys' Eyes Only” shall include any document, file, portion of file, transcribed testimony or other material that the Designating Party in good faith reasonably believes comprises trade secrets or other competitive sensitive confidential information, financial or other commercial or personally sensitive information that requires such heightened protection. Designated Material may be designated “Highly Confidential - Attorneys' Eyes Only” only if the Designating Party believes in good faith that designation as “Confidential” will not provide adequate protection.

         3. SCOPE

         The protections conferred by this Order cover not only Designated Material (as defined above), but also (1) any information copied or extracted from Designated Material; (2) all copies, excerpts, summaries, or compilations of Designated Material; and (3) any testimony, conversations, or presentations by parties or their counsel that might reveal Designated 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.

         4. ACCESS TO AND USE OF DESIGNATED MATERIAL

         4.1 Basic Principles. A receiving party may use Designated 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. Designated Material may be disclosed only to the categories of persons and under the conditions described in this Order. Designated Material must be stored and maintained by a receiving party at a location and in a secure manner that reasonably ensures that access is limited to the persons authorized under this Order.

         4.2 Disclosure of “Confidential” Information or Items. Unless otherwise ordered by the court or permitted in writing by the Designating Party, material designated as “Confidential” may be disclosed only to the following persons:

(a) the receiving party;
(b) the receiving party's counsel of record in this action, as well as employees of counsel to whom it is reasonably necessary to disclose the information for this litigation;
(c) the officers, directors, and employees (including in house counsel) of the receiving party to whom disclosure is reasonably necessary for this litigation;
(d) experts and consultants to whom disclosure is reasonably necessary for this litigation and who have signed the “Acknowledgment and Agreement ...

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