United States District Court, W.D. Washington, Seattle
LONGYEAR MALNATI & AHRENS, PLLC Elizabeth A. Hanley, WSBA
# 38233 Reed Longyear Malnati & Ahrens, PLLC Attorney for
KIOVSKY DUWALDT, LLC Elizabeth I. Kiovsky Kiovsky Duwaldt,
LLC Attorney for Defendant.
OFFICES OF THOMAS J. OWENS Thomas J. Owens, WSBA #23868 Law
Offices of Thomas J. Owens Attorney for Defendant.
STIPULATED PROTECTIVE ORDER
S. LASNIK, UNITED STATES DISTRICT COURT JUDGE
PURPOSES AND LIMITATIONS
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.
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
(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
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.
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.
ACCESS TO AND USE OF ...