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Woodell v. Expedia, Inc.

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

April 30, 2019

PATRICIA WOODELL, individually and on behalf of all others similarly situated,
v.
EXPEDIA, INC., EAN.COM, LP, TRAVELSCAPE, LLC and H0TELS.COM L.P., Defendants.

          HAGENS BERMAN SOBOL SHAPIRO LLP Steve Berman, WSBA# 12536 Andrew Volk, WSBA # 27639

          MCGOWAN, HOOD & FELDER, LLC James L. Ward, Jr. Ranee Saunders

          CALFO EAKES & OSTROVSKY PLLC Angelo J. Calfo, WSBA# 27079 Emily Dodds Powell, WSBA# 49351 Attorneys for Defendants Expedia, Inc., EAN.com, LP, Travelscape, LLC and Hotels.com L.P

          WALKER GRESSETTE FREEMAN & LINTON, LLC Ian W. Freeman John P. Linton, Jr. Attorneys for Plaintiff

          STIPULATED PROTECTIVE ORDER

          James L. Robart United State s 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; plaintiffs' personally identifiable information and financial records, including credit card information; non-public contractual terms with customers, suppliers, partners, and other parties;, non-public pricing, financial, and/or profit information; non-public business or operational, proprietary business, competitively sensitive, or trade secret information about Defendants; personal information about Defendants' employees (e.g., names, Social Security numbers, personal contact information, performance and evaluation information, disciplinary information, personal financial and medical information); customers' names and personally identifiable information; all information, documents, or data that Defendants are obligated to protect as confidential either by contract or in order to protect and preserve the interests of a third party; information protected from disclosure by statute; and other information that is contemporaneously labeled or branded as confidential by the producing party in the normal course of business and the disclosure of which would, in the good faith judgment of the producing party, be detrimental to the producing party or its affiliates.

         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 maybe 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 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 information for this litigation;

         (b) the 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 Attorney's 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 ...


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