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Advanced Hair Restoration, LLC v. Hair Restoration Centers, LLC

United States District Court, W.D. Washington

January 22, 2018

ADVANCED HAIR RESTORATION, LLC, Plaintiff,
v.
HAIR RESTORATION CENTERS, LLC, Defendant.

          Stokes Lawrence, P.S. Leslie C. Ruiter (WSBA #28090) Lance A. Pelletier (WSBA #49030) Stokes Lawrence, P.S. Attorneys for Plaintiff Advanced Hair Restoration, LLC

          Newman Du Wors Durrance LLP Nathaniel Durrance (WSBA #41627) John Du Wors (WSBA #33987) Newman Du Wors Durrance LLP Attorneys for Defendant Hair Restoration Centers, LLC

          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:

. Customer lists and/or referral sources;
. Pricing lists and formulas;
. Personal / company financial information, such as tax returns, and revenue and profit statements;
. Proprietary business information and/or trade secrets, specifically including information regarding Advanced Hair Restoration's proprietary FUE procedures and other surgical techniques;
. Marketing budgets and contracts, strategies, marketing data, and related competitive information;
. Contracts or agreements with medical providers and other customers;
. Protected health information (“PHI”) as defined under HIPAA and Washington law. Notwithstanding any other provisions in this agreement, the parties agree that any PHI produced in the course of this litigation a) shall not be used for any purpose other than this litigation and b) shall be returned to the covered entity or destroyed at the end of this litigation, as required by 45 CFR 164.512(e)(1)(ii)(B).

         The parties retain the right to add to this list of Confidential material as may required by future discovery requests in this litigation.

         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 ...


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