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Octaviano v. Premier Pacific Seafoods, Inc.

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

March 26, 2018

OSCAR R. OCTAVIANO, Plaintiff,
v.
PREMIER PACIFIC SEAFOODS, INC. a Washington Corporation, and PHOENDC PROCESSOR, L.P., a Washington Limited Partnership, Defendants.

          Karen A. Kalzer, WSBA No. 25429 Helsell Fetterman LLP Attorneys for Plaintiff

          David W. Silke, WSBA No. 23761 Derek A. Bishop, WSBA No. 39363 Attorneys for Defendants Gordon & Rees LLP

          STIPULATED PROTECTIVE ORDER

          ROBERT S. LASNIK, UNITED STATES DISTRICT COURT 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 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(e). 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:

2.1 Any and all financial information, tax returns and/or information contained therein, profit and loss statements or any other financial information of any kind relating to any of the Parties or their affiliates which is not already in the public domain.
2.2 Any and all personal information about any of the Party's employees, excluding Plaintiff, or former employees, including, but not limited to their addresses, phone numbers, e-mail addresses or other contact information, payroll information, rate of pay, disciplinary history; work history, family information, financial information which is not already in th 5 public domain, social security numbers, or dates of birth, or any other private information which may be obtained through discovery.
2.3 The Defendants' customer list(s), information regarding a particular customer, customer pricing, or trade secret or proprietary business information or processes of the Defendant) which is not already in die public domain.
2.4 Medical and counseling records belonging to Plaintiff.

         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 ...


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