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Linden v. X2 Biosystems, Inc.

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

March 1, 2018

CHARLES LINDEN and RONALD LANDER, Plaintiffs,
v.
X2 BIOSYSTEMS, INC., JOHN WU, CHRISTOPHER SIEGE, and BRIAN FLAIM Defendants.

          Christie J. Fix, WSBA #. 40801 FRANK FREED SUBIT & THOMAS LLP, Michelle Safro (admitted pro hac vice) REMENICK PLLC Attorneys for Plaintiffs Charles Linden and Ronald Lander

          Kenneth J. Diamond, WSBA # 27009 Winterbauer & Diamond, PLLC, Michael R. Gordon (admitted pro hac vice) Jay, J. Schecter (admitted pro hac vice) Gordon Law LLP Attorney for Defendants X2 Biosystems, Inc., John Wu, Brian Flaim, and Christopher Siege

          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 (Plaintiffs Charles Linden and Ronald Lander, and Defendants X2 Biosystems, Inc. (“X2”), John Wu, Christopher Siege, and Brian Flaim) 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.

         This Order shall not retroactively apply to or include any materials or documents produced prior to the entry of this Order.

         2. “CONFIDENTIAL” MATERIAL

         “Confidential” material shall include the following documents and tangible things produced or otherwise exchanged that are expressly designated as “CONFIDENTIAL MATERIAL” by (or at the request of) the party asserting the need for and applicability of such designation: (1) financial information of the parties, except for information related to X2's payment of wages and other employment benefits to the parties, and payments or loans made by any of the Defendants to Plaintiffs, or to one another; (2) sensitive personnel information relating to non-parties that X2 maintains as confidential within the company and does not disclose to third parties in the ordinary course of business; namely, medical and health information, payroll and benefits information that identify specific amounts of payroll and benefits information given to specific individuals, tax records, disciplinary and performance-related records, formal and informal performance appraisals, confidential settlements and confidential dispute resolutions with former X2 employees, officers, and/or directors; (3) non-public proprietary information, such as non-public intellectual property of X2; (4) non-public proprietary information of X2's customers or prospective customers, which may include non-public intellectual property.

         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; (3) written discovery or informal discovery that contains confidential information; and (4) 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 named parties in this matter, including 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 ...

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