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Pearce v. Irwin Naturals

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

July 27, 2017

THOMAS PEARCE, Plaintiff
v.
IRWIN NATURALS, registered in the State of Nevada as a Domestic Corporation; and a California State Foreign company, doing business in Washington State, Defendant. And VITAMIN SHOPPE, INC. “The Parent”, and VITAMIN SHOPPE INDUSTRIES, INC. the “Company”, a New Jersey based corporation dba SUPER SUPPLEMENTS, in the State of Washington, Defendant.

          LAW OFFICE OF CORNELIA CLARK CORNELIA CLARK, WSBA #26824 Attorneys for Plaintiff

          ANDREWS SKINNER, P.S. PAMELA M. ANDREWS, WSBA #14248 Attorneys for Defendant

          STIPULATED PROTECTIVE ORDER

          Thomas S. Zilly, United States District 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 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.

         2. “CONFIDENTIAL” MATERIAL

         “Confidential” material shall include the following documents and tangible things produced or otherwise exchanged: Plaintiff's medical records; any information; material or document that constitutes or reveals a trade secret; financial; proprietary or commercial information; specifically including Serious Adverse Event Reports (SAERs) and Adverse Event Reports (AERs); proprietary formula data; and the contract between the defendants.

         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 ...


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