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Brown v. Boeing Co.

United States District Court, W.D. Washington

April 9, 2018

ARLENE M. BROWN, Plaintiff,
v.
BOEING COMPANY, et al., Defendants.

          Arlene M. Brown Plaintiff, PRO SE.

          Roberta H. Kuehne 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 Order 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, but is not limited to, the following documents and tangible things produced both by the parties and by any third parties or otherwise exchanged: information regarding The Boeing Company's operations; any proprietary information regarding the engineering, manufacturing, or sales of The Boeing Company's aircraft; any of The Boeing Company's trade secrets; personal and financial information; employment, compensation, and pension or benefits information; and all other non-public, confidential, proprietary or commercial information that is not readily ascertainable through lawful means by the public or the party receiving the information designated Confidential (“Receiving Party”), or that which is subject to privacy protection under any federal, state, or local law.

         Except for values disclosed in the Complaint or specifically agreed to in writing as non-confidential, “Confidential” material includes Plaintiff Arlene Brown's personal financial information.

         3. SCOPE

         The protections conferred by this Order 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 Order 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 Order. 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 Order.

         4.2 Disclosure of “CONFIDENTIAL” Information or Items.

         Unless otherwise ordered by the Court or permitted in writing by the party designating information as Confidential (“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 Pro Se Party's assistants, who are limited to Rosemarie McKeeman in her role as Administrative Assistant, to whom it is reasonably necessary to disclose the information for this litigation provided that they sign the “Acknowledgment and Agreement to Be Bound” (Exhibit A), and agree to immediately return all originals and copies of any Confidential material. Plaintiff shall be responsible for ensuring that all originals and copies of any Confidential material disclosed to one of her identified assistants is immediately returned;

         (c) the officers, directors, and employees (including in-house counsel) of The Boeing Company 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;

         (d) experts and consultants to whom disclosure is reasonably necessary for this litigation and who have signed the “Acknowledgment ...


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