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Roness v. T-Mobile USA, Inc.

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

April 22, 2019

ARTHUR RONESS, Plaintiff,
v.
T-MOBILE USA, INC., Defendant.

          PREMIER LAW GROUP PLLC Patrick Kang, WSBA #30726 Attorneys for Plaintiff

          SEBRIS BUSTO JAMES Jeffrey A. James, WSBA #18277 Matthew R. Kelly, WSBA #48050 Attorneys for Defendant

          STIPULATED MOTION AND PROTECTIVE ORDER

          RICARDO S. MARTINEZ CHIEF UNITED STATES DISTRICT JUDGE

         Plaintiff Arthur Roness and Defendant T-Mobile USA, Inc., by and through their respective counsel of record, hereby move pursuant to Federal Rule of Civil Procedure (26)(c) for entry of this Stipulated Protective Order:

         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. DESIGNATED MATERIALS

         “Designated Materials” shall include the documents, tangible items, or testimony produced, elicited, or otherwise exchanged in this action which the party producing such materials (the “Designating Party”) designates as “Confidential” or “Highly Confidential - Attorneys' Eyes Only.” Designated Materials may include, but are not limited to, customer information, personal, medical and/or other sensitive information of Defendant's employees, including Plaintiff, nonpublic personal information about any persons other than the parties, and sensitive or confidential financial or other proprietary information.

         2.1 Designated Materials marked “Confidential” shall include any document, file, portion of file, transcribed testimony or other material that the Designating Party in good faith reasonably believes comprise confidential information related to employees, third parties, or other information that could cause commercial, professional, or personal harm through disclosure. Designated Materials shall also include any and all medical records of any person obtained by any party, regardless of how the records were obtained or whether the records are marked “Confidential.”

2.2 Designated Materials marked as “Highly Confidential - Attorneys' Eyes Only” shall include any document, file, portion of file, transcribed testimony or other material that the Designating Party in good faith reasonably believes comprises competitive, financial or other commercial or personally sensitive information that requires such heightened protection. Designated Materials may be designated “Highly Confidential - Attorneys' Eyes Only” only if the Designating Party believes in good faith that designation as “Confidential” will not provide adequate protection.

         3. SCOPE

         The protections conferred by this Order cover not only Designated Materials (as defined above), but also (1) any information copied or extracted from Designated Materials; (2) all copies, excerpts, summaries, or compilations of Designated Materials; and (3) any testimony, conversations, or presentations by parties or their counsel that might reveal Designated Materials 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. ACCESS TO AND USE OF DESIGNATED MATERIALS

         4.1 Basic Principles. A receiving party may use Designated Materials that are 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. Designated Materials may be disclosed only to the categories of persons and under the conditions described in this Order. Designated Materials 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 Order.

         4.2 Disclosure of “Confidential” Information or Items. Unless otherwise ordered by the Court or permitted in writing by the Designating Party, material designated as “confidential” or medical information/records even if not so designated may be disclosed only 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 litigation;
(b) the parties to this litigation, including any officers, directors, and employees (including in house counsel) of the receiving party to whom disclosure is reasonably necessary for this litigation, unless the parties agree that a particular document or material produced is for “Highly Confidential - 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 to Be Bound” (Exhibit A);
(d) mediators, including their staff, retained by the Parties, and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);

         (e) the Court, Court personnel, and court reporters and their staff;

         (f) copy or imaging services retained by counsel to assist in the duplication of Designated Materials, provided that counsel for the party retaining the copy or imaging service instructs the service not to disclose any Designated Materials to third parties ...


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