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Castillo v. United Rentals (North America), Inc.

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

March 15, 2018

RICARDO CASTILLO, individually and on behalf of all others similarly situated, Plaintiff,
v.
UNITED RENTALS (NORTH AMERICA), INC., Defendant. v.

          STIPULATED PROTECTIVE ORDER

          THE HONORABLE JAMES L. ROBART.

         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 may include the following documents and tangible things produced or otherwise exchanged:

a) personally identifying information of the producing party or the producing party's employees, customers, or.third parties;
b) data regarding compensation earned by or paid to employees;
c) data reflecting sales of products and services, including information about the volume and types of sales, sales leads, sales incentives, or sales goals;
d) customer account information, such as names, telephone numbers, account numbers, or balances;
e) information about the producing party's computer information systems (including but not limited to systems and applications used in managing commission and compensation functions), general hardware and software specifications, and related instructions and training information;
f) employee trainings, internal policies, and evaluation materials;
g) employee personnel files;
h) the financial books and records of the producing party and information pertaining to those financial books and records;
i) information about the revenues, costs, expenses, profits and losses of the producing parly;
j) information about the producing party's short- and long-term business plans;
k) information that the producing party has regarding its customers, competitors, suppliers, vendors, and subcontractors;
1) information discussing, mentioning, or referring to the producing party's product development, design, or specifications;
m) any information that the producing party is obligated by contract or state or federal law to keep confidential;
n) any other information the producing party's business competitors could use to obtain a business or legal advantage ...

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