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Senior Housing Assistance Group v. Amtax Holdings 260, LLC

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

March 28, 2018

SENIOR HOUSING ASSISTANCE GROUP, Plaintiff,
v.
AMTAX HOLDINGS 260, LLC, et al., Defendants. AMTAX HOLDINGS 260, LLC, et al., Counter-Plaintiffs,
v.
SENIOR HOUSING ASSISTANCE CORPORATION, et al., Counter-Defendants.

          Michael R. Scott, WSBA #12822 Jake Ewart, WSBA #38655 Jessica C. Kerr, WSBA #49866 Attorneys for Plaintiff

          Dennis H. Walters, WSBA #9444 Karr Tuttle Campbell Attorney for Counter-Defendants Steel Lake Enterprises, LLC, Lakewood Meadows Enterprises, LLC, Lynnwood Retirement Living, LLC, and Woodlands Associates, LLC

          David J. Burman, WSBA #10611 Steven D. Merriman, WSBA #44035 Attorneys for Defendants

          Eric Pettit Christopher G. Caldwell, pro hac vice Noah Perez-Silverman, pro hac vice Eric Pettit, pro hac vice Boies Schiller & Flexner Attorneys for Defendants

          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 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:

(a) Information that the designating party reasonably believes constitutes, reflects, or discloses trade secrets, proprietary data, or commercially sensitive information;
(b) Information about employees or contractors that is treated as confidential by the designating party or affiliate, or by customers, vendors, or others with whom the designating party does business;
(c) Information subject to confidentiality agreements with third parties or pre-existing confidentiality agreements between the parties;
(d) Tax returns and information used in preparation of those tax returns;
(e) Medical records; and
(f) Tenant and other personal information.

         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 ...


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