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Home v. Altrider, LLC

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

November 7, 2017

LOK HOME, an Ohio citizen, Plaintiff,
v.
ALTRIDER, LLC, a Washington Limited Liability Company; JEREMY LEBRETON, a Washington citizen; and DOES 1 through 10, inclusive, Defendants.

          GORDON & REES LLP John V. Leary Allen W. Estes, III, WSBA# 34526 Attorneys for Lok Home

          TOUSLEY BRAIN STEPHENS PLLC James Bulthuis Jason T. Dennett, WSBA #30686 Attorneys for Jeremy LeBreton

          STIPULATED PROTECTIVE ORDER

          RICARDO S. MARTINEZ CHIEF 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:

a. Trade secret information as defined in the Uniform Trade Secrets Act, RCW 19.108.010;
b. Proprietary and competitive business information;
c. Information relating to design for products sold, developed, or under consideration for development, not otherwise accounted for in the preceding two subsections, but which are specific to AltRider.
d. Personal information where disclosure of that information would violate a person's privacy; and

         Financial information (including but not limited to tax return, financial statements, banking records, point-of-sale records, brokerage records, financial books and records, and electronic data containing financial 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 ...


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