United States District Court, W.D. Washington
BRETT MARTIN on behalf of himself and all others similarly situated, Plaintiff,
SUNLIGHT SUPPLY, INC., Defendant.
& GOLDEN LLP Jack A. Raisner, René S. Roupinian
Attorneys for Plaintiff
BUCKLEY LAW P.C.Marjorie A. Elken, Attorneys for Defendant
STIPULATED PROTECTIVE ORDER
S. Zilly, United States District Judge.
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. 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.
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.
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 CONFIDENTIAL MATERIAL
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.
Disclosure of confidential information and items.
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
(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 ...