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Dacumos v. Toyota Motor Credit Corp.

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

September 26, 2017

CAREN ROSE DACUMOS, Plaintiff,
v.
TOYOTA MOTOR CREDIT CORPORATION, a California Corporation, EQUIFAX INFORMATION SERVICES LLC, a Georgia Limited Liability Company, and EXPERIAN INFORMATION SOLUTIONS, INC., an Ohio Corporation, Defendants.

          SaraEllen Hutchison Attorney for Plaintiff Caren Rose Dacumos

          Todd O. Maiden (WSBA #14922) REED SMITH LLP Attorney for Defendant TMCC

          Katherine Neben JONES DAY Attorneys for Experian Information Solutions, Inc.

          Rachel L. Dunnington STOEL RIVES LLP Attorneys for Experian Information Solutions, Inc.

          Jeffrey M Edelson Attorney for Defendant Equifax Information Services LLC

          STIPULATED PROTECTIVE ORDER

          RICARDO S. MARTINEZ CHIEF UNITED STATES DISTRICT JUDGE

         IT IS HEREBY STIPULATED by and between Plaintiff Caren Rose Dacumos and Defendants Toyota Motor Credit Corporation (“TMCC”), Equifax Information Services, LLC (“Equifax”), and Experian Information Solutions, Inc. (“Experian”), through their respective attorneys of record, as follows:

         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. information prohibited from disclosure by statute;
b. information that the party has a reasonable and good faith belief contains a trade secret, including, but not limited to, disclosure logs, DR logs, transaction logs and admin reports;
c. research, technical, commercial or financial information that the party has maintained as confidential, and that, if disclosed to customers or competitors, would tend to damage the party's competitive position;
d. information and documents that a party has a reasonable and good faith belief constitutes, contains, or refers to proprietary technology or information owned or developed by the producing party, and that, if disclosed to customers or competitors, would tend to damage the party's competitive position, including, but not limited to, disclosure logs, DR logs, transaction logs, and Admin reports;
e. non-public competitive financial or business planning information that the producing party is prohibited by contract from revealing to third parties except in confidence, or has undertaken by contract with others to maintain its confidence.

         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 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 ...


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