United States District Court, W.D. Washington, Seattle
M. Crowley Impact Law Group PLLC, Jonah O. Harrison,
Attorneys for Defendant
Stephen A. Teller Teller and Associates, PLLC, William L.
Dixon Dixon Law Firm PLLC Attorneys for Plaintiffs
STIPULATED PROTECTIVE ORDER
C. COUGHENOUR, UNITED STATES DISTRICT JUDGE.
to the parties' stipulated motion for a protective order
(Dkt. No. 20), the Court ORDERS as follows:
PURPOSES AND LIMITATIONS
in this action involves 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.
material shall include the following documents and tangible
things produced or otherwise exchanged:
a. Non-party employee files;
b. Trade secrets (e.g., pricing information);
c. Medical records; and
d. Personal and corporate financial and tax information.
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.
ACCESS TO AND USE OF CONFIDENTIAL MATERIAL
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.
Disclosure of "CONFIDENTIAL" Information or
otherwise ordered by the court or permitted in writing by the
designating party, a receiving party may ...