United States District Court, W.D. Washington, Seattle
Englebrecht, Attorneys for Plaintiff.
Elizabeth K. Morrison, Gordon & Rees LLP, Attorneys for
Defendant Ace Metal Corporation.
STIPULATED PROTECTIVE ORDER
S. ZILLY UNITED STATES DISTRICT JUDGE.
PURPOSES AND LIMITATIONS
in this action involves 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.
material shall include the following documents and tangible
things produced or otherwise exchanged:
A. Ace Metal Corporation's Evaluation Report from its CPA
B. Ace Metal Corporation's Asset List
C. Ace Metal Corporation's Total Asset Value
D. Ace Metal Corporation's Profit and Loss Statements for
the year ending December 31, 2011, December 31, 2012,
December 31, 2013, December 31, 2014, December 31, 2015,
December 31, 2016, December 31, 2017
E. Ace Metal Corporation's Financial statements for 2013,
2014 and 2015
F. Ace Metal Corporation's Balance Sheet for 2014 G. Ace
Metal Corporation's Income Statement for 2014 H. Ace
Metal Corporation's Tax Returns for 2011, 2012, 2013,
2014, 2015, and
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.
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.
ACCESS TO AND USE OF CONFIDENTIAL MATERIAL
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.
Disclosure of “CONFIDENTIAL” Information or
Items. Unless otherwise ordered by the court or
permitted in writing by the designating party, a receiving