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Code Systems Corp. v. Murphy

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

March 1, 2018

CODE SYSTEMS CORPORATION d/b/a TURBO.NET, a Washington corporation, Plaintiff,
v.
LEANDER MURPHY, an individual, Defendant.

          DAVIS WRIGHT TREMAINE LLP Stuart R. Dunwoody, Arthur A. Simpson Attorneys for Plaintiff Code Systems Corporation d/b/a Turbo.net

          LITTLER MENDELSON, P.C. Ryan P. Hammond, Birgitte M. Gingold, Attorneys for Defendant Leander Murphy

          STIPULATED PROTECTIVE ORDER

         The parties stipulate and agree to this protective order.

         1. PURPOSES AND LIMITATIONS

         Discovery in this action is. likely to involve production of confidential, proprietary, or private information of the parties (and third parties) for which special protection may be warranted. Accordingly, the parties hereby stipulate to and petition the court to enter the following Stipulated Protective Order, which shah apply to all discovery in this action, including third-party discovery. 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 may be designated "CONFIDENTIAL" or "HIGHLY CONFIDENTIAL-ATTORNEYS'EYES ONLY."

         The following documents and tangible things produced or otherwise exchanged maybe designated "CONFIDENTIAL":

1. Documents containing financial information of one or more of the parties (or third parties);
2. Documents containing information related to the marketing, pricing and delivery of the goods or services of one or more the parties (or third parties);
3. Documents containing information related to business or legal processes and methods of one or more of the parties (or third parties);
4. Documents containing information regarding future product, development, branding/marketing strategies, and business plans of one or more of the parties (or third parties); and
5. Documents containing personally identifiable information (PII) pertaining to any individuals. .

         The following documents and tangible things produced or otherwise exchanged maybe designated "HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY":

1. Documents and tangible things produced or otherwise exchanged that would fall under the categories listed above but that the designating party in good faith reasonably believes to contain information of a particularly sensitive or confidential nature that warrants further restricted disclosure, such as trade secrets, certain pricing and financial information, certain business or legal processes and methods, certain future product, development, branding/marketing strategies, and business plans, or information the disclosure of which to another party or non-party would create a substantial risk of serious harm to the designating party that could not be avoided by less restrictive means-and documents and things may only be designated HIGHLY CONFIDENTIAL-ATTORNEY'S EYES ONLY if the designating party believes in good faith that designation as CONFIDENTIAL will not provide adequate protection.

         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 disclosed or produced by another party or by a non-party in connection with this case and that has been designated "CONFIDENTIAL" or "HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY" 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 material designated "CONFIDENTIAL" only to:

(a) the receiving party's outside counsel of record in this action, as well as employees of such counsel to whom it is reasonably necessary to disclose the ...

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