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International Brotherhood of Teamsters v. Alaska Air Group, Inc.

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

December 12, 2017

INTERNATIONAL BROTHERHOOD OF TEAMSTERS, AIRLINE DIVISION,
v.
ALASKA AIR GROUP, INC., and AIRLINE PROFESSIONALS ASSOC. OF THE INTERNATIONAL BROTHERHOOD OF TEAMSTERS, LOCAL UNION NO. 1224, Plaintiffs, and HORIZON AIR INDUSTRIES, INC., Defendants.

          Kathleen Phair Barnard WSBA No. 17896 Danielle Franco-Malone WSBA No. 40979 Schwerin Campbell Barnard Iglitzin & Lavitt LLP Darin M. Dalmat WSBA No. 51384 JAMES & HOFFMAN, P.C. Attorneys for Plaintiffs

          Kathleen Phair Barnard WSBA No. 17896 Danielle Franco-Malone WSBA No. 40979 Schwerin Campbell Barnard Iglitzin & Lavitt LLP Darin M. Dalmat WSBA No. 51384 JAMES & HOFFMAN, P.C. Attorneys for Plaintiffs

          STIPULATED PROTECTIVE ORDER

          Marsha J. Pechman 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: any documents or information that contains secret or proprietary information, treated as such by the party claiming confidentiality, and relating to its business or organization, the business or organization of its affiliates or subsidiaries or any entity that has or had a contractual relationship with it, its affiliates, or subsidiaries. It may include, without limitation, financial information, aircraft leasing information, aircraft and equipment acquisition information, budget planning, fleet information or planning, staffing and manpower strategy and information, labor cost data, products, customer lists and other customer information, pricing policies, employment records and policies, operational methods, strategic plans, marketing plans and strategies, product development techniques or plans, business acquisition plans, new personnel acquisition plans, methods of manufacture, technical processes, artwork, logos, trademark, design and design projects, inventions and research programs, trade “know-how, ” trade secrets, specific software, algorithms, computer processing systems, object and source codes, user manuals, system documentation, and other business affairs.

         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 Order do not cover information that (i) was publicly available through non-confidential sources prior to the commencement of this litigation and without the breach of any applicable confidentiality obligations when produced to a party; (ii) becomes publicly available through no fault of a recipient; or (iii) is developed by or on behalf of a recipient independently of and without reference to any Protected Material.

         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 lawsuit (Case No. 2:17-cv-001327-MJP). Without limiting the foregoing sentence, Protected Material may not be used by a receiving party in any other litigation, arbitration, or extra-judicial proceeding, whether such proceeding is between the parties or between the receiving party and a third party, without prior consent of the producing party. 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 and to immediately return all originals and copies of any confidential material;
(f) during their depositions, witnesses in the action to whom disclosure is reasonably necessary and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise agreed by the designating party or ordered by the Court. Pages of transcribed deposition testimony or exhibits to depositions that reveal confidential material must be separately bound by ...

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