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Magnuson v. BP West Coast Products, L.L.C.

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

September 19, 2017

DAVID B. MAGNUSON, Plaintiff,
v.
BP WEST COAST PRODUCTS, L.L.C., Delaware limited liability company; UNICAT CATALYST TECHNOLOGIES INC., a Texas for-profit corporation; and HYDROPROCESSING ASSOCIATES L.L.C., an Alabama for-profit limited liability company, Defendants.

          KRAFT DAVIES, P.L.L.C. Robert M. Kraft (via email agreement) Richard J. Davies (via email agreement) Marissa A. Olsson (via email agreement) Robert M. Kraft WSB No. 11096 Richard J. Davies WSB No. 25365 Marissa A. Olsson WSB No. 43488 Attorneys for Plaintiff.

          MILLER NASH GRAHAM & DUNN LLP K. Michael Fandel, Brie Coyle Jones K. Michael Fandel WSB No. 16281 Briana Coyle Jones WSB No. 46769 Attorneys for Defendant BP West Coast Products, LLC.

          GORDON THOMAS HONEYWELL LLP Joanne Thomas Blackburn WSB No. 21541 Attorneys for Defendant Hydroprocessing Associates L.L.C.

          SCHEER LAW GROUP LLP Nicholas R. Major (via email agreement), Dennis G. Woods (via email agreement) Nicholas R. Major WSB No. 49579 Dennis G. Woods, WSB No. 28713 Attorneys for Defendant Unicat Catalyst Technologies, Inc.

          STIPULATED PROTECTIVE ORDER

          THOMAS S. ZILLY 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:

         a.) Non-public financial information of the parties, the parties' current and former employees, or any other financial, economic, or beneficial interest created by or for the benefit of the parties' or the parties' current and former employees, including but not limited to accounting records, banking records, financial statements and tax returns;

         b.) Personal identification information of the parties, the parties' current and former employees, or any other financial, economic, or beneficial interest created by or for the benefit of the parties' or the parties' current and former employees, such as social security numbers, tax-payer identification numbers, and dates of birth; and

         c.) Non-public information that, if disclosed, would cause substantial harm to the position of any party with respect to its current competitors.

         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” ...


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