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QL2 Software LCC v. Laveau

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

March 12, 2018

QL2 SOFTWARE, LLC, a Delaware limited liability company, Plaintiff,
v.
THOMAS LAVEAU, an individual, Defendant.

          Lucinda J. Lake, Attorneys for Defendant and Counterclaimant Laveau CARNEY BADLEY SPELLMAN, P.S.

          David A. Sergenian, admitted pro hac vice Attorneys for Defendant and Counterclaimant Laveau SERGENIAN ASHBY LLP

          Daniel J. Bugbee, Dominique R. Scalia, DBS | LAW Attorneys for QL2 Software, LLC

          ORDER GRANTING JOINT MOTION AND STIPULATION FOR PROTECTIVE ORDER

          JAMES P. DONOHUE United States Magistrate Judge

         Pursuant to Federal Rules of Civil Procedure 26 and Local Rule 26(c), Defendant Thomas Laveau (“Laveau”) and Plaintiff QL2 Software, LLC's (“QL2”), jointly submit this stipulated proposed protective order for entry by the Court. This proposed protective order is based on the Court's Model Stipulated Protective Order. The sole modifications to the model order is the list of specific documents that has been inserted into Section 2 of the proposed order.

         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: sensitive financial information regarding Infare that Laveau is required to keep confidential; confidential communications with clients; confidential information in Laveau's QL2 personnel file; sensitive financial information of Laveau; confidential or proprietary information regarding QL2's business, customers, and personnel; QL2 financial information; information regarding Infare that QL2 is required to keep confidential.

         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 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 to Be Bound” (Exhibit A);

         (d) the court, court personnel, and court reporters and their staff;

         (e) copy or imaging services retained by counsel to assist in the duplication of confidential material, provided that counsel for the party retaining the copy or imaging service instructs the service not to disclose any confidential material to third parties and to immediately return all originals and copies of any confidential material;

         (f) during their depositions, witnesses in the action to whom disclosure is reasonably necessary and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise agreed by the designating party or ordered by the court. Pages of transcribed deposition testimony or exhibits to ...


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