United States District Court, W.D. Washington, Seattle
SaraEllen Hutchison Attorney for Plaintiff
G. Grant, Lisa M. Lawrence-Hughes (CBN 240375, admitted pro
hac vice) Yu Mohandesi LL Attorneys for Verizon Defendants
Jeffrey M. Edelson Markowitz Herbold PC Attorney for
Defendant Equifax Information Services LLC
Pham (California Bar #322899, Admitted Pro Hac Vice) JONES
DAY Rachel Groshong (WSBA #47021) STOEL RIVES LLP Attorneys
for Experian Information Solutions, Inc.
STIPULATED PROTECTIVE ORDER
RICARDO S. MARTINEZ CHIEF UNITED STATES DISTRICT JUDGE.
HEREBY STIPULATED by and between Plaintiff Judy Yee and
Defendants VERIZON DIGITAL MEDIA SERVICES, INC.
(“Verizon Media”), VERIZON WIRELESS SERVICES, LLC
(“Verizon Wireless”), EQUIFAX INFORMATION
SERVICES LLC (“Equifax”), EXPERIAN INFORMATION
SOLUTIONS, INC. (“Experian”), through their
respective attorneys of record, as follows:
PURPOSES 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 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.
“Confidential” material shall include the
following documents and tangible things produced or otherwise
a. information prohibited from disclosure by statute;
b. information that the party has a reasonable and good faith
belief contains a trade secret, including, but not limited
to, disclosure logs, D/R logs, transaction logs, admin
reports, and Defendants' confidential policies and
c. research, technical, commercial or financial information
that the party has maintained as confidential, and that, if
disclosed to customers or competitors, would tend to damage
the party's competitive position or expose an individual
to identity theft;
d. information and documents that a party has a reasonable
and good faith belief constitutes, contains, or refers to
proprietary technology or information owned or developed by
the producing party, and that, if disclosed to customers or
competitors, would tend to damage the party's competitive
position, including, but not limited to, Defendants'
confidential policies and procedures, disclosure logs, D/R
logs, transaction logs, and Admin reports.
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 or presentations
by parties or their counsel that might reveal confidential
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 AND 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 ...