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Eureka ! Pet Food, Inc. v. Ross-Wells, Inc.

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

July 13, 2018

EUREKA! PET FOOD, INC., a Florida Corporation, Plaintiff,
v.
ROSS-WELLS, INC., a Wisconsin Corporation, Defendant.

          O'NEIL, CANNON, HOLLMAN, DEJONG & LAING S.C. Laura Lavey Patrick G. McBride (Pro Hac Vice) HILLIS CLARK MARTIN & PETERSON P.S. Eric D. Lansverk, WSBA #17218 Mary Crego Peterson, WSBA #31593 999 Third Avenue, Suite 4600 Attorneys for Plaintiff

          YARMUTH WILSDON PLLC Diana S. Breaux, WSBA No. 46112 Molly A. Terwilliger, WSBA No. 28449 1420 Fifth Avenue, Suite 1400 Attorneys for Defendant Ross-Wells, Inc.

          STIPULATED PROTECTIVE ORDER

          MARSHA J. PECHMAN UNITED STATES SENIOR DISTRICT COURT 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:

• Documents relating to the parties' customers, including without limitation, documents reflecting customer contact information and purchase history;
• Documents relating to product sourcing or pricing;
• Documents relating to or reflecting product development or manufacturing, including, but not limited to, product formulas or recipes;
• Documents reflecting confidential and sensitive financial information, including without limitation, bank statements, profit and loss statements, financial statements, tax returns, or other similar records;
• Documents or other personal information regarding the parties' current and former principals or employees, including without limitation, personnel files.

         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. The parties further agree that all non-public material that is disclosed or produced by another party or by a non-party in connection with this case shall be used only for purposes of prosecuting, defending, or attempting to settle this litigation.

         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 ...

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