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Filby v. Equilon Enterprises LLC

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

June 20, 2019

ADAM FILBY, Plaintiff,



         This matter comes before the Court on the parties' joint motion for a stipulated protective order (Dkt. No. 21). The Court ENTERS the following:


         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 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.


         “Confidential” material may include the following documents and tangible things produced or otherwise exchanged: all documents concerning corrective actions, letters of commendation or reprimand, salary or pay information, performance evaluations, sick and vacation leave hours, personal financial records, medical records, other job positions Plaintiff applied for, information about applicants/candidates for those positions, Plaintiff's and other employee personnel files, and Defendant's financial information, customer and client information, Defendant's internal policies and procedures, Defendant's Puget Sound Refinery (“PSR”) business, strategy, organizational charts and reporting structures, Defendant's health and safety information and records at PSR, and all other private, proprietary information in a party's possession that is not generally available to employees or the public. The parties agree that a “Confidential” designation of documents that may fall into any of the above-described categories does not waive a party's right to challenge that designation. The parties also agree that the definition of “Confidential” material contained in this paragraph does not limit a party's right to designate other documents or materials that are not specifically enumerated herein.

         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, conversations, or presentations by parties or their counsel that might reveal confidential material. To the extent that testimony is deemed confidential, that designation must be affirmatively asserted, consistent with paragraph 5.2(b) below.

         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.


         4.1 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 at a location and in a secure manner that ensures that access is limited to the persons authorized under this agreement.

         4.2 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 in-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 ...

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