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Douglas v. Employbridge, LLC

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

June 21, 2019

KATHLEEN DOUGLAS, an individual, Plaintiff,
v.
EMPLOYBRIDGE, LLC, a California Limited Liability Company; EMPLOYMENT SOLUTIONS MANAGEMENT, INC., a Georgia corporation; and DOES 1 through 10, inclusive, Defendants.

          Kellie A. Tabor, WSBA #46260, M. Kathryne Bosbyshell, WSBA #47469 LITTLER MENDELSON, P.C. Attorneys for Defendants EMPLOYBRIDGE, LLC and EMPLOYMENT SOLUTIONS MANAGEMENT, INC.

          Kevin Smith, WSBA #48578 Defiance Law PLLC Attorneys for Plaintiff Kathleen Douglass

          STIPULATED PROTECTIVE ORDER

          Hon. James L. Robart United States District Judge

         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: Plaintiffs employment records; records related to Plaintiffs job searches and employment applications; Plaintiffs personal financial information; records of Defendants' other current and former employees; records related to employee compensation and benefits, both of Plaintiff and other current and former employees of Defendants; non-public records related to Defendants' Board of Directors; confidential information related to Defendants' business strategies and market planning; confidential communications regarding Defendants' manpower planning and decision making processes regarding layoffs; confidential financial information of Defendants; and, potentially, trade secret and confidential information related to Defendants' operations in the insurance industry, 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.

         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 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 ...


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