Searching over 5,500,000 cases.


searching
Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.

Linehan v. Pederson

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

April 10, 2018

MARSHA LINEHAN, an individual, Plaintiff,
v.
LANE PEDERSON, an individual, and COGNITIVE AND BEHAVIORAL SPECIALTIES d/b/a DIALECTICAL BEHAVIOR THERAPY NATIONAL CERTIFICATION AND ACCREDITATION ASSOCIATION, a Minnesota non-profit corporation, Defendants.

          KELLEY, GOLDFARB, HUCK, ROTH & RIOJAS, PLLC Christopher M. Huck, Kit W. Roth, R. Omar Riojas, CAIRNCROSS & HEMPELMANN, P.S. Ana-Maria Popp, Jeff Nelson, Binah B. Yeung, Attorneys for Plaintiff

          PERKINS COIE LLP William C. Rava, MOSS & BARNETT A Professional Association David P. Jendrzejek, (pro hac vice) Terese A. West (pro hac vice) Attorneys for Defendants

          AMENDED STIPULATED PROTECTIVE ORDER

          ROBERT S. LASNIK 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:

• confidential financial information, including personal financial statements, income source documents, and tax returns; and
• the rates and other terms and conditions applicable to training, consultation, therapy, and other goods and services provided by the parties using Plaintiffs alleged trademarks.

         This is an action between competitors. The foregoing information warrants protection for privacy reasons and to preserve confidential, proprietary information developed by the parties at their expense for a competitive advantage in providing such goods and services.

         The foregoing is not an acknowledgment by any party that any materials so listed above are relevant or discoverable for any purpose in this action.

         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 contain 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, the receiving party may disclose confidential information 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 parties to this action;
(c) experts and consultants to whom disclosure is reasonably necessary for this litigation and who have signed the "Acknowledgment and Agreement to ...

Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.