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Heydlauff v. Boeing Co.

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

August 3, 2017

NGELA HEYDLAUFF, Plaintiff,
v.
THE BOEING COMPANY, Defendants.

          BRESKM JOHNSON & TOWNSEND PLLC, Cynthia J. Heidelberg WSBA No.44121, Roger M. Townsend WSBA No.25525, Attorneys for Plaintiff Angela Heydlauff.

          FOX ROTHSCHILD LLP, Laurence A. Shapero WSBA No. 31301, Attorneys for Defendant The Boeing Company

          MORGAN, LEWIS & BOCKIUS, LLP, Matthew J. Sharbaugh, Christopher J. Banks, Attorneys for Defendant The Boeing Company.

          REVISED STIPULATED MOTION FOR ENTRY OF PROTECTIVE ORDER AND PROPOSED PROTECTIVE ORDER

          Honorable Robert S. Lasnik 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: financial information, confidential Boeing policies and procedures, personnel information concerning individuals not party to this action, documents concerning proprietary information and technology, and other similar documents (as applicable), as well as Plaintiffs medical records and other protected health information (as applicable).

         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) a party, the officers, directors, and employees (including in house counsel) of the receiving party to whom disclosure is reasonably necessary for this litigation;
(c) experts and consultants to whom disclosure is reasonably necessary for this litigation and who have signed the "Acknowledgment and Agreement to Be Bound" (Exhibit A), which includes each such person's clerical and support staff;
(d) the court, court personnel, and court reporters and their staff;
(e) copy or imaging services retained by counsel to assist in the duplication of confidential material, provided that counsel for the party retaining the copy or imaging service instructs the service not to disclose any confidential material to third parties and to ...

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