Searching over 5,500,000 cases.


searching
Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.

J. Rose & Associates, Inc. v. Baker Mills, Inc.

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

September 29, 2017

J. ROSE & ASSOCIATES, INC., Plaintiff,
v.
BAKER MILLS, INC., a Utah Corporation; KODIAK CAKES, LLC, a Delaware Limited Liability Company. Defendants.

          OSERAN HAHN.P.S. James H. Clark Attorney for Petitioner.

          OGDEN MURPHY WALLACE, PLLC Andrew Sachs Attorney for Defendants.

          STIPULATED PROTECTIVE ORDER

          The Honorable 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 includes but is not limited to the following documents and tangible things produced or otherwise exchanged: confidential business or personal information written or stored in any medium whatsoever, including but not limited to corporate financial records, sensitive business plans and communications, employee information, customer or account information (including data, proposals, bids, or personal information related to a customer), trade secrets, intellectual property (e.g., proprietary technical information), documents related to contracts and/or relationships with third parties where such relationships or the terms of such contracts are confidential or competitively sensitive, sensitive business documents which disclose the competitive practices or strategies of the company, and non-public financial information, 3. SCOPE

         The protections conferred by this agreement coyer 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 OSE 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 information for this litigation;
(b) the officers, directors and employees (including in house counsel) of the receiving party to whom disclosure is reasonably necessary for this litigation, unless the parties agree that a particular document or material produced is for Attorney's Eyes Only and is so designated;
(c) experts and consultants to whom disclosure is reasonably necessary for this litigation and who have signed the "Acknowledgment and Agreement to ...

Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.