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Martin v. Sunlight Supply, Inc.

United States District Court, W.D. Washington

June 27, 2018

BRETT MARTIN on behalf of himself and all others similarly situated, Plaintiff,
v.
SUNLIGHT SUPPLY, INC., Defendant.

          OUTTEN & GOLDEN LLP Jack A. Raisner, René S. Roupinian Attorneys for Plaintiff

          BUCKLEY LAW P.C.Marjorie A. Elken, Attorneys for Defendant

          STIPULATED PROTECTIVE ORDER

          Thomas S. Zilly, 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: personnel data, records, and files; payroll data and records; Defendant's financial records; documents concerning Defendant's financial status; documents or other information that is objectively private or contains financially sensitive information about a person or entity, such that disclosure of the information would likely have the effect of causing substantial harm to the person or entity; and, documents or other information that is otherwise entitled to protection under FRCP 26.

         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 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 and items.

         Unless otherwise ordered by the court or permitted in writing by the designating party, use of any information, documents, or portions of documents marked “CONFIDENTIAL, ” including all information derived therefrom, shall be restricted solely to the following persons:

(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) any party to an action who is an individual, and the officers, directors, and employees (including in house counsel) of the receiving party to whom disclosure is reasonably necessary for this litigation, unless a particular document or material produced is for Attorneys' 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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