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Skrifvars v. Istream Planet Co.

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

July 25, 2017

JASON SKRIFVARS, an individual, Plaintiff,
ISTREAM PLANET CO., a Delaware Corporation Defendant.

          Davis Wright Tremaine LLP Attorneys for iStreamPlanet Co., LLC Paula L. Lehmann, WSBA #20678 Angela R. Vogel, WSBA #34516 ISREALS NEUMAN PLC Attorney for Plaintiff David Neuman, WSBA #34516 GUSTAFSON NICOLAI PC Attorneys for Plaintiff J. Ryan Gustafson, Admitted pro hac vice


          Thomas S. Zilly United States District Judge


         Discovery in the above-captioned action (the “Action”) is likely to involve production of confidential, proprietary, or private information, as more fully defined in Section 2 below (collectively “Protected Material”) for which special protection may be warranted. Accordingly, the parties hereby stipulate to and petition this 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.



         “CONFIDENTIAL” materials: Any documents (whether electronic or hard copy), discovery responses or deposition testimony, exhibits to depositions and hearings, portions of briefs or other court filings containing confidential, proprietary, or private information, including without limitation, financial information, trade secrets, personnel and compensation information or other commercially sensitive or personally sensitive information of a non-public nature or which is subject to third party confidentiality restrictions or obligations, may be designated as confidential (regardless of whether such designation is made by a party or by a non-party). Additionally, “Confidential” material shall include, but not be limited to, the following documents and tangible things produced or otherwise exchanged:

• Financial and business information;
• Stock Option Plans and related information;
• Stock valuations and related information;
• Personnel records of employees, including information related to compensation and participation in stock option plans;
• Tax information;
• Information subject to a legally protected right of privacy; and
• Any other information not in the public domain and that is reasonably and in good faith believed by the producing party to contain trade secret, proprietary, confidential or sensitive information.

         “CONFIDENTIAL-ATTORNEYS' EYES ONLY” material shall include all or any part of any Confidential material, the disclosure of which to another Party or non-party would create a substantial risk of serious injury that could not be avoided by less restrictive means.

         By designating materials as “CONFIDENTIAL-ATTORNEYS' EYES ONLY” the designating parties and their counsel represent they have a good faith belief that the materials so designated are not only Confidential but contain extremely sensitive and confidential proprietary or personal information, including, without limitations, trade secrets and such information relating to third parties that could be used by a party to the direct and material detriment of the Designating Party.

         3. SCOPE

         The protections conferred by this agreement cover not only Protected Material (as defined above), but also (1) any information copied or extracted from Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected Material; and (3) any testimony, conversations, or presentations by parties or their counsel that might reveal Protected 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 Protected Material that is disclosed or produced by another party or by a non-party in connection with this Action only for prosecuting, defending, or attempting to settle the same, and shall not be used for any other purpose. Protected Material may be disclosed only to the categories of persons and under the conditions described in this agreement. Protected 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 ...

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