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Puget Soundkeeper Alliance v. Seattle Iron & M S Corp.

United States District Court, W.D. Washington

April 25, 2018

PUGET SOUNDKEEPER ALLIANCE, Plaintiff,
v.
SEATTLE IRON & M S CORP., Defendant.

          Claire E. Tonry, WSBA #44497 Attorney for Plaintiff.

          Stephen R. Parkinson, WSBA #21111 Attorneys for Defendant.

          JOINT 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: Seattle Iron & M s Corporation and Subsidiaries Consolidated Financial Statements.

         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 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, a receiving party may disclose any confidential material only to:

(a) the receiving party's counsel of record in this action, as well as counsel of record's legal assistant to whom it is reasonably necessary to disclose the information for this litigation;
(b) the Executive Director of the receiving party to whom disclosure is reasonably necessary for this litigation, however, disclosure shall be limited to references to the financial statements in unredacted expert reports (including drafts), unredacted pleadings (including drafts) and attorney settlement memoranda citing the financial statements. The Executive Director shall not review the financial statements themselves nor make any notes regarding the contents of the financial statements based on references in the unredacted expert reports, unredacted pleadings, and attorney settlement memoranda;
(c) the receiving party's economist expert to whom disclosure is reasonably necessary for this litigation and who has signed the “Acknowledgment and ...

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