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Uchytil v. Avanade Inc.

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

June 20, 2017

MARIA UCHYTIL, on behalf of the United States of America, Plaintiff,
AVANADE INC., a Washington corporation, and AVANADE FEDERAL SERVICES, a Delaware corporation, ACCENTURE FEDERAL SERVICES LLC, a Delaware limited liability corporation, Defendants.

          CALFO EAKES & OSTROVSKY PLLC Angelo J. Calfo, Damon C. Elder KIRKLAND & ELLIS LLP Craig S. Primis, Pro Hac Vice Liam P. Hardy, Pro Hac Vice Devin S. Anderson, Pro Hac Vice Kirkland & Ellis LLP Attorneys for Defendants Avanade, Inc., Avanade Federal Services LLC, and Accenture Federal Services LLC

          LOWE GRAHAM JONES, PLLC Mark P. Walters, Ellen M. Bierman, Lowe Graham Jones, PLLC, SCHLEMLEIN GOETZ FICK & SCRUGGS PLLC Mark K. Davis, Robert L. Olson, Schlemlein Goetz Fick & Scruggs PLLC Attorneys for Relator Maria Uchytil




         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 entitle parties to file confidential information under seal.


         “Confidential” material shall include the following documents and tangible things produced or otherwise exchanged: (1) contractual terms with customers, vendors, and other parties; (2) pricing, financial, and/or profit information; (3) suppliers and supplier lists; (4) customers, customer lists, and customer technical requirements; (5) product development information and information relating to new products; (6) development processes, designs, drawings, engineering, and hardware and software configuration information; (7) marketing plans, business plans, forecasts, and business strategies; (8) sensitive communications and information relating to products and services, including, but not limited to, testing and quality control records, which in the hands of competitors would be valuable; (9) customer feedback regarding products that have not been publicly disclosed; (10) protected personal information (including contact information) and other information subject to privacy laws; (11) internal financial reporting; (12) sensitive business information, akin to the categories specified above, produced by a non-party; and (13) communications with U.S. government agencies containing sensitive non-public 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 the public domain through trial or otherwise.


         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.

         “CONFIDENTIAL” information and material must be stored in the United States and accessed and viewed by United States citizens only, including permitted disclosures pursuant to section 4.2.

         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 ...

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