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Johnson v. Boeing Co.

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

September 28, 2017

RALPH G. JOHNSON, Plaintiff,
v.
THE BOEING COMPANY, a Delaware corporation, and BARBARA WILEY, individually and on behalf of her marital community, Defendants.

          Date of Filing: May 5, 2017

          LIFE 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 BOEING COMPANY

          MOTION TO APPROVE STIPULATED PROTECTIVE ORDER

          ROBERT S. LASNIK 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:

         All 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.

         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 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 ...

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