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Northshore Sheet Metal Inc. v. Sheet Metal Workers International Association

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

May 20, 2019

NORTHSHORE SHEET METAL, INC., Plaintiff,
v.
SHEET METAL WORKERS INTERNATIONAL ASSOCIATION, LOCAL 66 Defendant.

          Christopher L. Hilgenfeld Attorneys for Plaintiff

          Daniel Hutzenbiler Richard G. McCracken Paul L. More Attorneys for Defendant.

          AMENDED STIPULATED PROTECTIVE ORDER

          Honorable Barbara J. Rothstein United States District Court Judge.

         1. PURPOSES AND LIMITATIONS

         Discovery in this action is likely to continue to involve production of confidential, proprietary, or private information for which special protection may be warranted. Due to the filing of the Second Amended Complaint in this action, the parties hereby stipulate to and petition the court to enter the following Amended Stipulated Protective Order ("this agreement"). 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 applicable legal principles, and it does not presumptively entitle parties to file confidential information under seal. The terms of this amended Stipulated Protective Order shall govern all discovery materials previously produced in this action, to discovery materials produced pending the Court's entry of the Stipulated Order, and to discovery materials produced subsequent to the Court's entry of the Stipulated Order.

         2. "CONFIDENTIAL" MATERIAL

         "Confidential" material shall include the following documents and tangible things produced or otherwise exchanged: financial construction bid information, proprietary technical information, contract pricing information, customer lists, specifications, designs, process information, technical data, organizing methods, labor or business campaign strategy, internal processes, marketing/public-relations and business plans.

         3. ATTORNEY EYES ONLY MATERIAL

         "ATTORNEY EYES ONLY" material shall include documents and tangible things produced or otherwise exchanged that contain information which is business, union, and/or proprietary information regarding future or potential construction, that, if released to competitors or collective-bargaining counterparts, would confer a competitive advantage, interfere with collective-bargaining relationships, or interfere with associational-privacy rights protected by the U.S. Constitution and laws including Section 7 of the National Labor Relations Act, including: confidential research and development, financial construction bid infonnation, contract pricing information, proprietary technical information, customer lists, technical data, organizing methods, labor or business campaign strategy, internal processes, marketing/public-relations and business plans.

         4. 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.

         5. ACCESS TO AND USE OF CONFIDENTIAL MATERIAL

         5.1 Basic Principles. A receiving pa1iy 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. All "Confidential" documents or "Attorney's Eyes Only" documents produced in this case shall be used solely for the purposes of this litigation and no other purposes. 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.

         5 .2 Disclosure of "CONFIDENTIAL" Information or Items. 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 house counsel) of the receiving party to whom disclosure is reasonably necessary for this litigation, unless the parties agree that a particular document or material produced is for Attorney's Eyes Only and is so designated;

         (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 ...


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