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Veridian Credit Union v. Eddie Bauer LLC

United States District Court, W.D. Washington

August 7, 2017

VERIDIAN CREDIT UNION, on behalf of itself and a class of similarly situated financial institutions Plaintiff,
v.
EDDIE BAUER LLC, Defendant,

          By: KimD. Stephens By: Kathleen A, . Nelson Kim D. Stephens,

          By: Chase C. Alvord Chase C. Alvord, By: Sarah E. Demaree TOUSLEY BRAIN STEPHENS PLLC Sarah E. Demaree,

          By: JonP. Kardassakis Jon P. Kardassakis, Joseph P. Guglielmo Erin G. Comite, pro hac vice SCOTT䠣, ATTORNEYS AT LAW, LLP By: /si'Dvanne J. Cho.

          LEWIS BRISBOIS BISGAARD Gary F. Lynch, pro hac vice Kevin W. Tucker, pro hac CARLSON LYNCH SWEET KILPELA & CARPENTER, LLP Attorneys for Defendant

          Eddie Bauer LLC Karen H. Riebel, pn? hac vice Kate Baxter-Kauf, pro hac vice LOCKRIDGE GRINDALNAUEN P.L.L.P.

          Arthur M. Murray MURRAY LAW FIRM Brian C. Gudmundson ZIMMERMAN REED, LLP Bryan L. Bleichner, /?ro hac vice

          CHESTNUT CAMBRONNE PA Attorneys for Plaintiff Veridian Credit Union

          STIPULATED MOTION FOR PROTECTIVE ORDER

          Hon. Jams t L. Robart United States District Court Judge

         1- PURPOSES AND LIMITATIONS

         Discovery in this action is likely to involve production of confidential, proprietary, or private information for which special protection, including clawback rights, 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:

a. Trade secrets;
b. Non-privileged materials relating to information governance, information technology architecture and data security;
c. Non-privileged materials relating to law enforcement investigations into data security incidents;
d. Payment card industry investigations into data security incidents;
e. Non-privileged investigations into data security incidents;
f. Personally identifiable information as defined by various federal and state statutes;
g. Non-privileged remedial steps taken in response to data security incidents.

         3. SCOPE

         The protections conferred by this agreement cover not only confidential material (as defined above), but also (1) any information copied, extracted or derived 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 ...


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