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Meyer v. Bayerische Motoren Werke AG

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

May 21, 2018

HOWARD J. MEYER, JR. AND DARLIS L. ELLIOTT, Plaintiffs,
v.
BAYERISCHE MOTOREN WERKE AG aka BMW MOTORRAD; BMW of NORTH AMERICA, LLC; and DMC SIDECARS LLC; Defendants.

          Michael W. Flanigan, WSBA #34939 FLANIGAN & BATAILLE Attorneys for Plaintiffs

          Peter Steilberg, WSBA #22190 MERRICK HOFSTEDT & LINDSEY, P.S. Attorneys for Defendants BMW NA and BMW AG

          Michael G. Brady, WSBA #32912 BRADY LAW OFFICE Attorneys for Defendant DMC Sidecars, LLC

          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:

         Protocol and procedures for dealers involved with BMW 1200 GS and GSA motorcycles potentially subject to recall; sales statistics regarding BMW motorcycles and the number of motorcycles involved (inspected and/or subject to inspection);

         Design information and technical information about the BMW 1200 GS and GSA motorcycles, including the forks;

         Technical information about the work involved in the recall, including retrofitting of the front forks;

         Recall decision documents;

         Personal identifiers and other personal or private information about any individual identified in records maintained by BMW NA or BMW AG, including, without limitation, information that may be the subject of German Data Privacy Law (FDPA) and any related privacy law) or the privacy laws of a nation with a law that applies to the data maintained by BMW NA or BMW AG;

         Personal identifiers and other personal or private information listed in Fed. R. Civ. Pro. 5.2 and Local Civil Rule 5.2.

         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 ...


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