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Dawud v. The Boeing Co.

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

July 17, 2018

KIFAYA DAWUD, Plaintiff,



         This matter comes before the Court on Plaintiff Kifaya Dawud's (“Plaintiff”) and Defendant the Boeing Company's (“Boeing”) unopposed motion for protective order (Dkt. No. 19). Having thoroughly considered the motion and the relevant record, the Court finds good cause to enter the following protective order.


         Discovery in this action will 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 Order is consistent with Local Civil Rule 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.


         “Confidential” material shall include, but is not limited to, the following documents and tangible things produced by both parties and by any third parties or otherwise exchanged: information or documents regarding Boeing's operations; any private or proprietary information regarding the sales and marketing of Boeing's aircraft (including customer or potential customer information and communications related to any customer or potential customer); any of Boeing's trade secrets; social security numbers, birthdates, employment information (including any documents or information related to performance management and Boeing's investigations related in any manner to a current or former employee, including EEO, ethics, and any other investigation performed by Boeing or its agents), compensation, benefits information, all protected health information (including medical records received pursuant to subpoena or otherwise produced in the action), and any other personal and financial information of Plaintiff and any third party (including non-party current or former Boeing employees); and all other non-public, confidential, proprietary, or commercial information that is not readily ascertainable through lawful means by the public or the party receiving the information designated as Confidential (“Receiving Party”), or that which is subject to privacy protection under any federal, state, or local law.

         Where desired, the party designating information or documents as Confidential (the “Designating Party”) may redact social security numbers, birth dates, residential addresses and phone numbers, and non-relevant customer information in lieu of using the Confidential designation.

         3. SCOPE

         The protections conferred by this Order 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 Order do not cover information that is in the public domain or becomes part of the public domain through trial or otherwise.


         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 Order. Confidential material must be stored and maintained by the Receiving Party at a location and in a secure manner that ensures that access is limited to the persons authorized under this Order.

         4.2 Disclosure of “CONFIDENTIAL” Information or Documents.

         Unless otherwise ordered by the Court or permitted in writing by the Designating Party, a Receiving Party may only disclose Confidential material 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 Boeing to whom disclosure is reasonably necessary for this litigation;
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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