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Yee v. Verizon Digital Media Services Inc.

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

June 18, 2019

JUDY YEE, Plaintiff
v.
VERIZON DIGITAL MEDIA SERVICES, INC., a California Corporation, and VERIZON WIRELESS SERVICES, LLC, d/b/a VERIZON WIRELESS, a Delaware Limited Liability Company, EQUIFAX INFORMATION SERVICES, LLC, a Georgia Limited Liability Company, EXPERIAN INFORMATION SOLUTIONS, INC., an Ohio Corporation and TRANS UNION LLC, a Delaware Limited Liability Company, Defendants.

          SaraEllen Hutchison Attorney for Plaintiff

          Donald 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

          Bao 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.

         IT IS 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:

         1. PURPOSES AND LIMITATIONS

         Discovery 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.

         2. “CONFIDENTIAL” MATERIAL “Confidential” material shall include the following documents and tangible things produced or otherwise exchanged:

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 procedures;
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.

         3. 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 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.

         4. ACCESS TO AND USE OF CONFIDENTIAL MATERIAL

         4.1 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 ...


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