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Oberloh v. Giorgio Armani Corp.

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

May 8, 2019

CAROLE OBERLOH, Plaintiff,
v.
GIORGIO ARMANI CORP., a New York corporation; Defendant.

          TELLER & ASSOCIATES, PLLC Stephen Teller, WSBA #23372 Attorney for Plaintiff

          JACKSON LEWIS P.C. Michael A. Griffin, WSBA #21903 Sherry Talton, WSBA #42780 520 Attorneys for Defendant

          MODEL STIPULATED PROTECTIVE ORDER, AS AMENDED AND JOINTLY PROPOSED

          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 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:

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

         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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