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Kremerman v. Open Source Steel, LLC

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

August 25, 2017

ELLIOT KREMERMAN, Plaintiff,
v.
OPEN SOURCE STEEL, LLC, et al., Defendants.

          Stephen E. Morrissey Lindsey Godfrey Eccles SUSMAN GODFREY L.L.P. Attorneys for Plaintiff Elliot Kremerman

          Rick C. Chang (Admitted Pro Hac Vice) Duane H. Mathiowetz (Admitted Pro Hac Vice) FOLEY & LARDNER LLP Benjamin Hodges, WSBA No. 49301 FOSTER PEPPER PLLC Attorneys for Defendants Open Source Steel, LLC, James Dellay, and Joshua Dellay

          STIPULATED PROTECTIVE ORDER

          BRIAN A. TSUCHIDA, UNITED STATES MAGISTRATE 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

         2.1 “CONFIDENTIAL” material may include, but is not limited to, the following documents and tangible things produced or otherwise exchanged:

• Supplier or manufacturer lists of plaintiff, defendants, and any of their businesses;
• Proprietary or non-public information regarding composition, formula, and manufacturing specifications of the products marketed and sold by plaintiff, defendants, and any of their businesses.

         2.2 “HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY” material shall include extremely sensitive confidential information or items, disclosure of which to another Party or Non-Party would create a substantial risk of serious harm that could not be avoided by less restrictive means, and may include but are not limited to:

• Sensitive, highly proprietary, or trade secret company information, including financial information of the plaintiff, defendants, and any of their businesses (including, but not limited to, profits, losses, costs, and sales figures);
• Customer lists of the plaintiff, defendants, and any of their businesses.

         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) the receiving party and the officers, directors, and employees (including in house counsel) of the receiving party to whom disclosure is reasonably necessary for this litigation, unless a particular document ...


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