United States District Court, W.D. Washington
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.
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: Seattle Iron & M
s Corporation and Subsidiaries Consolidated Financial
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 CONFIDENTIAL MATERIAL
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.
Disclosure of “CONFIDENTIAL” Information or
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
(c) the receiving party's economist expert to whom
disclosure is reasonably necessary for this litigation and
who has signed the “Acknowledgment and ...