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Nguyen v. CenturyLink, Inc.

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

April 18, 2018

THUYHONG NGUYEN, an individual Plaintiff,
v.
CENTURYLINK, INC., a Louisiana corporation Defendant.

          REED LONGYEAR MALNATI & AHRENS, PLLC Elizabeth A. Hanley, WSBA # 38233 Reed Longyear Malnati & Ahrens, PLLC Attorney for Plaintiff.

          KIOVSKY DUWALDT, LLC Elizabeth I. Kiovsky Kiovsky Duwaldt, LLC Attorney for Defendant.

          LAW OFFICES OF THOMAS J. OWENS Thomas J. Owens, WSBA #23868 Law Offices of Thomas J. Owens Attorney for Defendant.

          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(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) The various applicable versions of the CenturyLink Sales Compensation Agreement between the parties;
(B) The applicable Business Unit (“BU”) Master Guide (“BU Master Guide”), and any documents, forms, and tables specifically attached to or incorporated into the BU Master Guide;
(C) Compensation information regarding employees other than Plaintiff;
(D) Documents containing the claims submitted through the CenturyLink issue tracking system (“ITS”) by employees other than Plaintiff;
(E) Personnel information regarding employees other than 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 ...


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