United States District Court, W.D. Washington, Seattle
Eckman, William H. Walsh, Attorneys for Plaintiff.
Allison K. Krashan, Attorneys for Defendant.
Schueler, Pro Hac Vice, Attorneys for Defendant.
C. COUGHENOUR UNITED STATES DISTRICT JUDGE.
to the parties' stipulation and proposed order (Dkt. No.
17), the Court hereby ENTERS the following protective order:
PURPOSE 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 W.D. Wash.
Local Civil Rule 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: baler design history
files; baler prints; baler design and engineering
specifications; baler drawings; and documents related to the
design, manufacture and materials for balers.
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 AN USE OF CONFIDENTIAL MATERIAL
Basic Principles. 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.
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 ...