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Bolding v. Banner Bank

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

July 27, 2018

KELLY BOLDING and MICHAEL MANFREDI, individually and on behalf of a class of all others similarly situated, Plaintiffs,
v.
BANNER BANK, a Washington Corporation, Defendant.

          THE BLANKENSHIP LAW FIRM, P.S. Attorneys for Plaintiffs Scott C. G. Blankenship, Richard E. Goldsworthy, Charlotte S. Sanders.

          DAVIS WRIGHT TREMAINE LLP Attorneys for Defendant Banner Bank Kenneth E. Payson, Sheehan Sullivan Ryan Hess, Laura-Lee Williams.

          STIPULATED PROTECTIVE ORDER

          ROBERT S. LASNIK UNITED STATES 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 stipulate to and enter into the following agreement regarding discovery, which the parties respectfully ask the court to enter as a 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 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, data, and tangible things produced or otherwise exchanged:

a) compensation and overtime plans, along with documents discussing those plans to the extent they contain private information relating to individual employees, or other information Banner believes is proprietary;
b) policies and procedures regarding commissions, overtime, or other compensation earned by or paid to employees to the extent they contain private information relating to individual employees or information Banner believes is proprietary;
c) personally identifying information of the producing party or the producing party's employees or customers, including but not limited to proprietary customer information;
d) private data regarding commissions, overtime, or other compensation earned by or paid to individual employees, or other information that is proprietary;
e) data reflecting sales of loan services, including but not limited to information about the volume and types of sales, sales leads, sales incentives, or sales goals;
f) non-public customer account information, including but not limited to customers' names, dates of birth, drivers' license numbers, social security numbers, addresses, telephone numbers, account numbers, routing numbers, mortgage or other loan numbers, mortgage loan applications, background checks, credit scores and reports, financial or asset statements or information, tax returns or tax-related forms like W-2s, account balances, and the like;
g) proprietary information about the producing party's computer information systems (including but not limited to systems and applications used in managing commission, overtime, and other compensation functions), general hardware and software specifications, and related instructions and training information;
h) proprietary employee training and evaluation materials;
i) employee personnel files;
j) the financial books and records of the producing party and information pertaining to those financial books and records;
k) information that the producing party has regarding its customers and its competitors;
l) the producing party's contracts with suppliers, vendors, customers, contractors, subcontractors;
m) any information that the producing party is obligated by contract or state or federal law to keep confidential; and
n) any other information the producing party's business competitors could use to obtain a business or legal advantage ...

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