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USI Insurance Services National, Inc. v. Ogden

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

July 13, 2018

USI INSURANCE SERVICES NATIONAL, INC. formerly known as WELLS FARGO INSURANCE SERVICES USA, INC., a North Carolina corporation, Plaintiff,
v.
STANLEY OGDEN, an individual; MARCIA OGDEN, an individual; ELEANOR L'KEEFE, an individual; LEWIS DORRINGTON, an individual; JOHN HASKELL, JR., an individual; MARY MARK, an individual; ABD INSURANCE AND FINANCIAL SERVICES, INC., a Delaware corporation, Defendants.

          JAMES G. ZISSLER (WSBA #30287) LITTLER MENDELSON, P.C. ATTORNEYS FOR PLAINTIFF

          THOMAS P. HOLT (WSBA #39722) LITTLER MENDELSON, P.C. ATTORNEYS FOR PLAINTIFF

          EMILY R. CARDENAS (WSBA #43180) LITTLER MENDELSON, P.C. ATTORNEYS FOR PLAINTIFF

          JUSTO G. GONZALEZ (WSBA #39127) STOKES LAWRENCE, P.S. ATTORNEYS FOR DEFENDANTS

          JAIME CUEVAS, JR. (WSBA #51108) STOKES LAWRENCE, P.S. ATTORNEYS FOR DEFENDANTS

          AMENDED STIPULATED PROTECTIVE ORDER

          ROBERT S. LASNIK, 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 be limited to information not in the public domain contained in the following documents and tangible things produced or otherwise exchanged:

(a) The identity of and non-public information regarding the parties' customers;
(b) The parties' non-public and proprietary financial, accounting, and commercial information, non-public and proprietary data or applications, or other proprietary or trade secret information;
(c) Information the producing party is obligated to maintain as confidential by contract or otherwise.

         As used herein, “confidential material” includes material designated as “CONFIDENTIAL” unless clearly stated otherwise. The foregoing reference to categories of material, shall not constitute an admission or concession, or permit any inference, that the parties agree that the documents and information identified are, in fact, properly discoverable or relevant, nor shall it foreclose any party from objecting to the disclosure of any of the above listed information and/or moving the Court for an order to prevent the disclosure of such information, document or thing, and the parties specifically reserve all of their rights to do so.

         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 or Items.

         Unless otherwise ordered by the court or permitted in writing by the designating party, a receiving party may ...


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