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Haram Corp. v. United States

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

May 7, 2019

HARAM CORPORATION, a Washington for profit Corporation, d/b/a DREXEL DELI & GROCERY, et al., Plaintiffs,
v.
UNITED STATES OF AMERICA, Defendant.

          Andrew Tapp Attorney for Plaintiffs

          Pooja Faldu Davé, NY Bar #5011804 Attorney for Defendant

          ORDER

          JOHN C. COUGHENOUR, UNITED STATES DISTRICT JUDGE.

         Pursuant to the parties' stipulation and proposed order (Dkt. No. 17) the Court ENTERS the following 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 Western District of Washington 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 the parties to file confidential information under seal.

         2. “CONFIDENTIAL” MATERIAL

         “Confidential” material shall include the following documents and tangible things produced or otherwise exchanged:

(a) Applicable portions of the administrative record containing information exempt from disclosure under the Food and Nutrition Act of 2008;
(b) Governmental records containing information exempt from disclosure under the Food and Nutrition Act of 2008;
(c) Applicable portions of records prepared in relation to the USDA investigation of Plaintiffs containing information exempt from disclosure under the Food and Nutrition Act of 2008;
(d) Portions of deposition transcripts containing information exempt from disclosure under the Food and Nutrition Act of 2008; and
(e) Any financial information not publicly filed with any federal or state regulatory authority.

         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 ...


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