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Riverkeeper v. Crunch Pak, LLC

United States District Court, E.D. Washington

May 20, 2019

COLUMBIA RIVERKEEPER, Plaintiff,
v.
CRUNCH PAK, LLC, Defendant.

          PROTECTIVE ORDER

          ROSANNA MALOUF PETERSON, UNITED STATES DISTRICT JUDGE

         BEFORE THE COURT is the parties' Proposed Stipulated Protective Order, ECF No. 19. Having reviewed the protective order proposed by the parties, and the remaining record, the Court finds good cause to grant the motion and enter the agreed-upon protective order.

         Accordingly, IT IS HEREBY ORDERED that the parties' Stipulated Motion for Protective Order, ECF No. 19, is GRANTED. The protective order is set forth below:

1. Plaintiff Columbia Riverkeeper and Defendant Crunch Pak, LLC and their respective counsel (collectively the “parties”) have stipulated that discovery in this action is likely to involve production of confidential, proprietary, or private information-including, but not limited to, confidential commercial and financial information-for which special protection may be warranted. This agreement does not confer blanket protection on all disclosures or responses to discovery. Instead, 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. The procedures that must be followed and the standards that will be applied when a party seeks permission from the Court to file material under seal will be governed by applicable law.
2. As used in this order, the term “Confidential Material” means documents or information which contain proprietary technical or commercial or information designated as such by a party producing such information, and constituting trade secrets, confidential know-how, proprietary information, and the like, which relates to a product or products or a commercial operation used or proposed to be used, or which relates to or contains research or commercial information generated by said party, whether revealed during a deposition, in a document, in an interrogatory answer or otherwise, in connection with this litigation. This definition shall include, but is not limited to, any and all documents or information relating to the financial operations or assets, or general financial status, of one of the parties.
3. Any document, any written statement, and any copy, excerpt, synopsis, summary or note pertaining to any such document or statement, or to any oral statement which contains confidential information, shall be bates stamped conspicuously with the word “CONFIDENTIAL” prior to production. A party producing “CONFIDENTIAL” documents will segregate the documents as to which confidentiality is claimed, provide a list of said documents, or otherwise “flag” the documents so that other parties are notified of the claims.
4. 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.
5. 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 may be 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.
6. 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;
c. experts and consultants to whom disclosure is reasonably necessary for this litigation and who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
d. the court, court personnel, and court reporters and their staff;
e. copy or imaging services retained by counsel to assist in the duplication of confidential material, provided that counsel for the party retaining the copy or imaging service instructs the service not to disclose any confidential material to third parties and to ...

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