United States District Court, W.D. Washington, Seattle
RALPH G. JOHNSON, Plaintiff,
THE BOEING COMPANY, a Delaware corporation, and BARBARA WILEY, individually and on behalf of her marital community, Defendants.
of Filing: May 5, 2017
POINT LAW Bryan C. White, Esq. WSBA # 44064 LIFE POINT LAW
Attorneys for Plaintiff RALPH JOHNSON
MORGAN, LEWIS & BOCK1US LLP FOX ROTHSCHILD LLP Laurence
A. Shapero, MORGAN, LEWIS & BOCKIUS LLP Melinda S.
Riechert (pro hac vice) MORGAN, LEWIS & BOCKIUS LLP Sacha
M. Steenhoek (pro hac vice) Attorneys for Defendant THE
MOTION TO APPROVE STIPULATED PROTECTIVE
S. LASNIK UNITED STATES DISTRICT JUDGE
PURPOSES AND LIMITATIONS
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.
material shall include the following documents and tangible
things produced or otherwise exchanged:
documents, interrogatory responses, admissions, depositions,
other pretrial or trial testimony, medical records, EEO or
other Boeing investigative reports, employee performance or
disciplinary documents (including but not limited to
Corrective Action Memoranda), and other discovery materials
produced, served, or given by a party to this litigation, and
all third party provider information that is disclosed in
connection with a signed authorization or release by a party
to this litigation, may be designated by the party producing
or authorizing the disclosure of such material or testimony
as "Confidential" if they contain information
relating to the medical conditions and restrictions of
third-parties who have a reasonable expectation of privacy
and if they contain information regarding private employment
information regarding third-party employees.
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
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 ...