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Santamour v. UPS Ground Freight Inc.

United States District Court, E.D. Washington

October 13, 2017

CHRISTOPHER A. SANTAMOUR, et al., Plaintiffs,
v.
UPS GROUND FREIGHT, INC., Defendant.

          Charles N. Eberhardt, WSBA No. 18019, Chelsea Dwyer Petersen, WSBA No. 33787, Javier F. Garcia, WSBA No. 38259, Perkins Coie LLP, Attorneys for Defendant United Parcel Service Ground Freight, Inc.

          India Lin Bodien, WSBA No. 44898 India Lin Bodien, Attorney at Law, Craig J. Ackermann Craig J. Ackermann (CA State Bar No. 229832) Ackermann & Tilajef, P.C., Attorneys for Plaintiffs

          STIPULATED PROTECTIVE ORDER

          THOMAS O. RICE, Chief United States District Judge

         STIPULATION

         Plaintiffs Christopher Santamour and John Peightal, by and through their undersigned counsel, and Defendant UPS Ground Freight, Inc. (“UPS Freight”), by and through its undersigned counsel, hereby agree to the entry of the Protective Order below.

         PROTECTIVE ORDER

         Pursuant to FRCP 26(c) and the stipulation of the parties, the Court hereby enters the following Protective Order.

         1.Confidential Matter

         a. As used herein, “Confidential Matter” shall mean any document, information, or specific portions thereof, furnished in the course of litigation- during discovery or otherwise-that both (1) is marked or stamped by a party as “Confidential” in accordance with subsection 1(b) below, and (2) contains the following:

i. Non-public and private personal information, including documents containing personal financial information or contact information; or
ii. Confidential and proprietary business information that provides the party with a business advantage over its competitors. To the extent that documents relate to matters that UPS Freight takes significant steps to protect in its daily operations, such as through the use of non-disclosure and confidentiality agreements with its employees (if any), such information can be designated as Confidential Matter.

         b. The determination of whether produced material is Confidential Matter shall be made in the first instance by the party from whom discovery is sought. Each party that designates information or documents for protection under this agreement must take care to limit any such designation to specific material that qualifies under the appropriate standards. The designating party must designate for protection only those parts of material, documents, items, or oral or written communications that qualify as Confidential Matter, so that other portions of the material, documents, items, or communication for which protection is not warranted are not swept unjustifiably within the ambit of this Order.

         Mass, indiscriminate, or routinized designations are prohibited. Designations that are shown to be clearly unjustified or that have been made for an improper purpose expose the designating party to sanctions. The protections conferred by this Order do not cover information that is in the public domain or becomes part of the public domain through litigation or otherwise.

         If there is a disagreement between the parties as to whether particular produced materials have been properly designated as Confidential, the dispute may be ...


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