United States District Court, E.D. Washington
Office of Thomas G. Jarrard, PLLC, Attorneys for Plaintiff.
J. Kisch, Karin D. Jones, Christopher T. Wall, STOEL RIVES
LLP Attorneys for Defendant.
STIPULATED PROTECTIVE ORDER
THOMAS O. RICE UNITED STATES DISTRICT COURT JUDGE.
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
hereby stipulate to and petition the court to enter the
following Stipulated Protective Order. The parties
acknowledge that this agreement 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:
1. DEA's contract documents;
2. DEA's personnel and salary records;
3. information protected from disclosure by statute or other
4. trade secrets of a party or non-party;
5. non-public financial or other sensitive commercial
information, including but not limited to business or
strategic plans and internal cost, budget, productivity, and
revenue tracking reporting information; and
6. any other sensitive, confidential, proprietary, trade
secret documents or information that may be target of
discovery in this action.
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.
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.
ACCESS TO AND USE OF CONFIDENTIAL MATERIAL
information may be used only for purposes of 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.
Disclosure of “CONFIDENTIAL” Information or
otherwise ordered by the court or permitted in writing by the
designating party, a receiving party may ...