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Spektor v. Saltworks, Inc.

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

May 7, 2018

REEM SPEKTOR, Plaintiff,
v.
SALTWORKS, INC., et al., Defendants.

          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

          JOHN C. COUGHENOUR UNITED STATES DISTRICT JUDGE

         Pursuant to the parties' stipulation and proposed order (Dkt. No. 13) the Court ENTERS the following protective order:

         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:

• Plaintiff's health care records and health insurance records;
• Either party's tax, accounting, or financial information;
• Defendants' confidential and sensitive personnel and payroll documents or data;
• Defendants' proprietary and trade secret documents or data.

         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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