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Rio v. Ipeco Holdings, Ltd.

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

June 11, 2018

LOURDES DEL RIO, et al., Plaintiffs,
v.
IPECO HOLDINGS, LTD., et al., Defendants.

          Brett Bustamante Hunter Shkolnik Attorneys for Plaintiffs

          Todd Rosencrans Rachel Constantino-Wallace Attorneys for Defendant The Boeing Company

          Richard Walker Marnie Holz Attorneys for Defendant Ipeco Holdings Ltd.

          ORDER

          JOHN C. COUGHENOUR, UNITED STATES DISTRICT JUDGE.

         1. PURPOSES AND LIMITATIONS

         This product liability case arises from an October 3, 2014 in-flight incident aboard a Boeing Model 777 aircraft operated by American Airlines. The incident allegedly involved a sudden descent that allegedly caused the physical and emotional injuries detailed in the Complaint. Plaintiffs allege that the incident was caused by alleged defects in the first officer's flight deck seat fore/aft power switch. Accordingly, discovery in this action is likely to involve production of confidential, proprietary, export controlled, and 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 and/or Export Controlled” material shall include the following documents and tangible things produced or otherwise exchanged:

(a) Plaintiffs' medical records;
(b) Plaintiffs' employment records;
(c) Plaintiffs' financial information related to alleged past and future wage loss;
(d) Defendants' documents related to the design, manufacture, testing and certification of the Model 777 aircraft flight deck, including the flight deck seats.

         3. SCOPE

         The protections conferred by this agreement cover Confidential material (as defined in Section 2, above), and Export Controlled material (as defined in Section 5, below), as well as (1) any information copied or extracted from Confidential or Export Controlled material; (2) all copies, excerpts, summaries, or compilations of Confidential or Export Controlled material; and (3) any testimony, conversations, or presentations by parties or their counsel that might reveal Confidential or Export Controlled material.

         Further, these protections apply to Confidential and Export Controlled material produced in connection with this litigation by any person or entity regardless of whether the person or entity producing or receiving the Confidential or Export Controlled material is a party to this litigation.

         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 employees of counsel to whom it is reasonably necessary to disclose the information for this litigation;
(b) the officers, directors, and employees (including in house counsel) of the receiving party to whom disclosure is reasonably necessary for this litigation, unless the parties agree that a particular document or material produced is for Attorney's Eyes Only and is so designated;
(c) experts and consultants to whom disclosure is reasonably necessary for this litigation and who have signed the “Acknowledgment and Agreement ...

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