United States District Court, W.D. Washington, Seattle
& ASSOCIATES, PLLC Stephen Teller, WSBA #23372 Attorney
JACKSON LEWIS P.C. Michael A. Griffin, WSBA #21903 Sherry
Talton, WSBA #42780 520 Attorneys for Defendant
MODEL STIPULATED PROTECTIVE ORDER, AS AMENDED AND
S. Lasnik, United States District Court Judge.
PURPOSES AND LIMITATIONS
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.
material shall include the following documents and tangible
things produced or otherwise exchanged:
1) Agreed portions of non-party personnel files;
2) Defendant's customer contact or financial information;
3) Defendant's vendor agreements;
4) Defendant's financial performance information;
5) Documents containing trade secrets or other confidential
business information, such as pricing, competitive strategy,
forward-looking projections, etc.;
6) Information marked "confidential" in any other
lawsuit involving the parties
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.
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.
ACCESS TO AND USE OF ...