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Cristalla Condominium Association v. Affiliated FM Insurance Co.

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

June 1, 2017

CRISTALLA CONDOMINIUM ASSOCIATION, a Washington nonprofit corporation, Plaintiff,
v.
AFFILIATED FM INSURANCE COMPANY, a foreign insurance company, Defendant.

          Thomas M. Williams Attorneys for Plaintiff.

          Scott M. Stickney. Attorneys for Defendant.

          STIPULATED CONFIDENTIALITY AND [PROPOSED] PROTECTIVE ORDER

          Hon. Robert S. Lasnik United States District Court 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 Confidentiality and Protective Order. The parties acknowledge mat this agreement is consistent with Fed. R Civ. P. 26(c) and any and all Local Rule counterparts. 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 applicable legal principles, and it does not presumptively entitle parties to file confidential information under seal.

         2. "CONFIDENTIAL" MATERIAL

         "Confidential" material shall include die following documents and tangible things produced or otherwise exchanged: (1) Documents that contain confidential, commercial, proprietary, and/or internal business information that is valuable to the business of Factory Mutual Insurance Company and/or Affiliated FM Insurance Company (collectively "FM Global") and which, if not treated as confidential, may provide FM Global Y competitors an unfair advantage in competition (such as, for example, and without limitations, various internal training manuals, procedures, or other such documents of FM Global; and (2) personal, confidential and/or proprietary information relating to Plaintiff Cristalla Condominium Association and its business, financial information, officers and/or employees; as well as certain personal and/or commercial information the dissemination of which could subject the parties to annoyance, embarrassment, or oppression.

         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 the public domain through trial or otherwise.

         4. ACCESS TO AND USE OF CONFIDENTIAL MATERIAL

         4.1 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 agreement. Confidential material must be stored and maintained by a receiving party at a location and in a secure manner that ensures that access is limited to the persons authorized under this agreement.

         4.2 Disclosure of "CONFIDENTIAL" Information or Items. Unless otherwise ordered by the court or permitted in writing by the designating party, a receiving party may disclose any confidential material only to:

(a) 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;
(b) the officers, directors, and employees (including in-house counsel) of the receiving party to whom disclosure is reasonably necessary for this litigation, unless the parties agree that a particular document or material produced is for Attorney's Eyes Only and is so designated;
(c) experts and consultants to whom disclosure is reasonably necessary for this litigation and who have signed the "Acknowledgment and Agreement to ...

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