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In re Petition of PJSC Uralkali

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

May 17, 2019

IN THE MATTER OF THE PETITION OF PJSC URALKALI FOR AN ORDER PURSUANT TO 28 U.S.C. § 1782 TO CONDUCT DISCOVERY FOR USE FN A FOREIGN PROCEEDING

          Davis Wright Tremaine LLP Attorneys for Respondent John E. McCaw, Jr.

          Brad Fisher, WSBA #19895 920 and Gregory P. Joseph Joseph Hage Aaronson LLC Keller Rohrback, L.L.P. Attorneys for Applicant PJSC Uralkali

          STIPULATED PROTECTIVE ORDER [PROPOSED]

          Hon. James L. Robart United States District Judge

         WHEREAS, on October 22, 2018, Applicant PJSC Uralkali ("Applicant") filed a petition in the above-captioned action (the "Action") for an order pursuant to 28 U.S.C. § 1782 (the "Petition") allowing Applicant to serve a subpoena for documents and testimony from Respondent John E. McCaw, Jr. ("Respondent" and together with Applicant, the "Parties" and each a "Party"), for use in an action brought September 27, 2018 by Applicant against Mr. Geoffrey Rowley & Mr. Jason Baker, as administrators of Force India Formula One Team Limited (in administration), Claim No. BL-2018-002138 (High Court of Justice, Business and Property Courts of England & Wales, Business List (Ch)) (the "English Action");

         WHEREAS, on January 23, 2019, this Court issued an order granting Applicant's Petition;

         WHEREAS, Applicant is agreeing to enter into this confidentiality agreement which provides that any discovery materials obtained pursuant to this 28 U.S.C. § 1782 proceeding may be used or disclosed only in (i) this Action, (ii) the English Action, and (iii) the deposition of John Idol, in No. 18-mc-00459 (ER) (S.D.N.Y.) (the "Idol Deposition"), and providing other reasonable protections that Respondent may require;

         WHEREAS, Applicant and Respondent believe that good cause exists for the entry of this order, which is narrowly tailored to protect Respondent's non-public, confidential, personal, proprietary, private, or commercially sensitive information for which special protection from public disclosure is warranted;

         By reason of the foregoing, the Court hereby enters the following Protective Order ! (hereinafter, "Protective Order") in this proceeding.

         1. This Protective Order shall apply to all of Respondent's documents and information that are produced or disclosed in any form by Respondent, including in any hard copy or electronic document, or in testimony given at his deposition, and all information copied or extracted from any of the above (collectively, "Discovery Materials"). Applicant, and any other person receiving any Discovery Materials, are together referred to herein as "Receiving Parties" and each a "Receiving Party."

         2. No Discovery Materials may be used or disclosed by any Receiving Party, except in (i) this Action, (ii) the English Action, and (iii) the Idol Deposition.

         3. Respondent may designate any Discovery Materials as "Confidential" under the terms of this Protective Order if Respondent reasonably believes in good faith that such Discovery Materials contain non-public, confidential, personal, proprietary, or commercially sensitive information that meets the requirements of Federal Rule of Civil Procedure 26(c) for the protections provided in this Protective Order ("Confidential Discovery Materials"). 4. Discovery Materials Respondent wishes to designate as Confidential Discovery Materials shall be so designated in the following manner:

a. In the case of documents or other materials (apart from depositions or other pre-trial testimony): (i) by affixing the legend "Confidential" to each page containing any Confidential Discovery Materials; or (ii) in the case of electronically stored information produced in native format, by including "Confidential" in the file or directory name, or by affixing the legend "Confidential" to the media containing the Confidential Discovery Materials.
b. With respect to Discovery Materials that contain Confidential Discovery Materials produced in electronic form, the same designation shall be affixed to the medium on which the Confidential Discovery Materials is provided.
c. With respect to deposition transcripts and exhibits thereto that contain Confidential Discovery Materials, the designation shall be made (1) on the record at the deposition or (2) within thirty (30) days after the transcript becomes available to those who have ordered a copy, on written notice of the "Confidential" designation to all counsel of record for the Parties by: (i) marking the cover page of the transcript with the legend "Contains Confidential information: Subject to Protective Order"; (ii) affixing the legend "Confidential" to each page containing any ...

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