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Central Freight Lines, Inc. v. Amazon Fulfillment Services

United States District Court, W.D. Washington

December 15, 2017

CENTRAL FREIGHT LINES, INC., a Texas Corporation Plaintiff,
v.
AMAZON FULFILLMENT SERVICES, a Delaware corporation, and DOES 1 through 25, inclusive, Defendants.

          Marc H. Kallish (admittedpro hac vice), Garry Wills (admitted pro hac vice), Roetzel & Andress Attorneys for Plaintiff

          Jacob M. Downs, WSBA No. 37982 Corr Downs PLLC Attorneys for Plaintiff ED: December 15, 2017

          Tim J. Filer, WSBA No. 16285 Steven W. Block, WSBA No. 24299 Christopher A. Rogers, Attorneys for Defendants

          ORDER STIPULATED PROTECTIVE ORDER

          Honorable James L. Robart United States District Court 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 information may be designated "Confidential, " or "Attorneys' Eyes Only." "Confidential" material shall include commercial information that is not publicly known and is of technical or commercial advantage to its possessor, in accordance with Fed. R. 26(c)(7), or other information required by law or agreement to be kept confidential.

         "Attorneys' Eyes Only" material shall include information that the producing party deems especially sensitive, which may include (but is not limited to) trade secrets, confidential research and development, financial, technical, marketing, pricing and revenue information, and any other sensitive trade secret information, the disclosure of which to in-house counsel, officers, directors, and/or managers would create a substantial risk of serious harm that could not be avoided by less restrictive means.

         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 "Attorneys' 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 ...

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