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Equal Employment Opportunity Commission v. Hershey Co.

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

January 26, 2018

EQUAL EMPLOYMENT OPPORTUNITY COMMISSION, Plaintiff,
v.
THE HERSHEY COMPANY, Defendant.

          ROBERTA STEELE REGIONAL ATTORNEY, JOHN F. STANLEY SUPERVISORY TRIAL ATTORNEY, DAMIEN A. LEE SENIOR TRIAL ATTORNEY BY DAMIEN A. LEE ATTORNEYS FOR PLAINTIFF EQUAL EMPLOYMENT OPPORTUNITY COMMISSION

          BY MICHAEL J. PUMA, ERIC C. KIM MORGAN, LEWIS & BOCKIUS LLP, SHERYL J. WILLERT WILLIAMS KASTNER ATTORNEYS FOR DEFENDANT THE HERSHEY COMPANY

          STIPULATION OF CONFIDENTIALITY AND PROTECTIVE ORDER

          ROBERT S. LASNIK UNITED STATES DISTRICT JUDGE

         I. PURPOSES AND LIMITATIONS

         1. This Stipulation of Confidentiality and Proposed Protective Order (“Stipulation”) shall govern the use and disclosure of all “Discovery Materials, ” as defined below, which are created or produced in connection with the above-captioned action. “Discovery Materials” shall include transcripts of depositions upon oral examination and exhibits thereto; transcripts of depositions upon written questions and exhibits thereto; answers to interrogatories; documents, data, or other things produced by any party to any other, whether or not pursuant to a formal request; answers to requests for admission; documents or things produced by any non-party participating in this litigation (“non-party”) to any of the parties (defined below), whether or not pursuant to a subpoena; all information contained in any of the foregoing; and all copies, excerpts or summaries of any of the foregoing.

         2. 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.

         II. “CONFIDENTIAL” MATERIAL

         “Confidential” material shall include, but is not limited to, the following documents and tangible things produced whether by voluntary or compelled production or disclosure or in response to any formal discovery procedure or otherwise exchanged:

a. Medical records and healthcare information pertaining to Charging Party Kristina M. Williams (“Ms. Williams”), e.g., EEOC000411-413, EEOC000418-419.
b. Any proprietary business information or commercial information entitled to protection as now or hereafter interpreted by the Court, including product information, customer and other commercial agreements, financial information, sales information, pricing and promotion information, marketing information, strategic and/or planning information, product innovation or development information, and/or business reorganization information concerning Defendant The Hershey Company (“Hershey” or “Defendant”) or its affiliates, e.g., customer lists, sales data, documents reflecting merchandising strategy.
c. Any personal or private information concerning Ms. Williams who Plaintiff EEOC seeks relief for or, any other former or current employees of Hershey, e.g., Social Security Numbers, date of birth, and personal financial information.
d. Defendant's tax records, tax returns, intellectual property including trade secrets.
e. Personnel records and information related to nonparties, e.g., performance evaluations like EEOC000220-226 or termination records.

         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 ...


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