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PrepareMe America LLC v. Survival Prep Warehouse, LLC

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

October 2, 2017

PREPAREME AMERICA LLC, a Washington limited liability company, Plaintiff,
v.
SURVIVAL PREP WAREHOUSE, LLC, a Washington limited liability company, TANIA LORRAINE ANGEL, a/k/a Tania Lorraine Kahlor, a/k/a Tania Lorraine Biechler, a/k/a Tania Biechler Angel, MARK A. ANGEL, and the marital community composed thereof, Defendants,
v.
CHAD E. ALLEN, Third-Party Defendant.

          MATESKY LAW Michael P. Matesky, II (WSBA #39586) Counsel for PrepareMe America, LLC and Chad E. Allen

          RUTTLER MILLS, PLLC Daniel J. Mills (WSBA#39384) Mill Creek, WA 98012 CARNEY BADLEY SPELLMAN, P.S. John R. Welch (WSBA No. 26649) Counsel for Survival Prep Warehouse, LLC, Tania L. Angel, and Mark A. Angel

          STIPULATED PROTECTIVE ORDER

          Honorable Thomas S. Zilly 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: (1) lists or other documents comprising names or contact information of customers or former customers; (2) lists or other documents comprising names or contact information of suppliers; (3) non-public contracts or agreements, (4) trade secret information as defined in the Uniform Trade Secrets Act, chapter 19.108 RCW; (5) quality control procedures employed by a party; (6) non-public research and development, financial, technical, marketing, pricing, and revenue information; and, (7) non-public communications regarding prospective business relationships between a party or non-party and its customers, (8) information specifically identified as confidential or proprietary in agreements or other contemporaneous documents referring to such information.

         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 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 Be Bound” (Exhibit A);

         (d) the court, court personnel, and court reporters and their staff;

         (e) copy or imaging services retained by counsel to assist in the duplication of confidential material, provided that counsel for the party retaining the copy or imaging service instructs the service not to disclose any confidential material to third parties ...


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