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Puget Soundkeeper Alliance v. Ace Metal Corp.

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

September 19, 2017

PUGET SOUNDKEEPER ALLIANCE, Plaintiff,
v.
ACE METAL CORPORATION, Defendant.

          Alyssa Englebrecht, Attorneys for Plaintiff.

          Elizabeth K. Morrison, Gordon & Rees LLP, Attorneys for Defendant Ace Metal Corporation.

          STIPULATED PROTECTIVE ORDER

          THOMAS S. ZILLY UNITED STATES DISTRICT JUDGE.

         1. PURPOSES AND LIMITATIONS

         Discovery 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.

         2. “CONFIDENTIAL” MATERIAL

         “Confidential” material shall include the following documents and tangible things produced or otherwise exchanged:

A. Ace Metal Corporation's Evaluation Report from its CPA dated 9.29.2016
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

         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 ...


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