United States District Court, W.D. Washington, Seattle
Attorneys for Plaintiff Reem Spektor Reed Longyear Malnati
& Ahrens, PLLC Elizabeth A. Hanley, WSBA #38233
Attorneys for Defendant Saltworks, Inc. Davis Wright Tremaine
LLP Melissa K. Mordy Mary R. Sanden Melissa K. Mordy, WSBA
#41879 Mary R. Sanden, WSBA #45608 Davis Wright Tremaine LLP
STIPULATED PROTECTIVE ORDER
C. COUGHENOUR UNITED STATES DISTRICT JUDGE
to the parties' stipulation and proposed order (Dkt. No.
13) the Court ENTERS the following protective order:
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.
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:
• Plaintiff's health care records and health
• Either party's tax, accounting, or financial
• Defendants' confidential and sensitive personnel
and payroll documents or data;
• Defendants' proprietary and trade secret documents
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 ...