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Byron v. Institute for Environmental Health, Inc.

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

July 10, 2019

JAMES BYRON, Plaintiff,

          Stephani L. Ayers Thad M. Guyer T.M. Guyer and Ayers & Friends, P.C Attorneys for PlaintiffJames Byron

          Sarah E. Bouchard Sarah E. Bouchard (admittedpro hac vice) Bradley J. Crowell, Esq. (admittedpro hac vice. Tara Param (admittedpro hac vice) MORGAN, LEWIS & BOCKIUS LLP Laurence A. Shapero, WSBA No. 31301 Ogletree, Deakins, Nash, Smoak & Stewart, P.C. Attorneys for Defendant Institute for Environmental Health, Inc.



         Plaintiff James Byron ("Plaintiff) and Defendant Institute for Environmental Health, Inc. ("Defendant") (each a "Party" and collectively the "Parties") hereby stipulate, by and through their undersigned counsel, that the following provisions shall govern claims of confidentiality in the above-captioned action:

         1. Documents containing the following may be designated as "Confidential": trade secrets; special formulas; company security matters; customer lists; financial data; production data; matters relating to mergers and acquisitions; documents which related to pricing for company services; proprietary research, development, manufacturing, commercial, revenue and sales information; laboratory testing methods and procedures; personal records and information that include social security numbers, names of minors, non-public contact information, compensation, benefits, medical information, and performance evaluations or ratings (whether formal or informal). Such documents or parts thereof will be designated after review by an attorney for the producing party by stamping the word "Confidential" on each page, or, in the event a document is produced in its native format, the filename shall include the word "CONFIDENTIAL" in all capital letters between brackets, e.g.: IEH 2013 Financial Plan [CONFIDENTIAL] .doex. To the extent that matter stored or recorded in the form of electronic or magnetic media (including information, files, e-mails, databases, or programs stored on any digital or analog machine-readable device, computer, disc, network or tape) is produced in such form, the producing party or any other party may designate such material as Confidential by affixing a label on the media or its casing indicating such designation, accompanied by cover letter specifying the exact portions of the electronic or magnetic media that contains Confidential information.

         2. If a document is produced and inadvertently not marked "Confidential," the producing party may designate the document as Confidential by promptly notifying the receiving party in writing, of the "Bates" number (if such numbers have been placed on that document, and if not, otherwise identifying the document with specificity for the receiving party) of each page of the document that contains Confidential discovery material. The receiving party is subject to no repercussions under this order if said party shared the information prior to it being stamped CONFIDENTIAL.

         3. Documents and testimony designated as Confidential shall be shown only to:

a. Court reporters, stenographers, or video graphers working on this action;
b. Outside and inside counsel who represent parties in this action, and regular and temporary employees of those counsel assisting in the conduct of this action, including independent contractors or businesses providing copying services or litigation support, for use in accordance with this Stipulation and Order;
c. Outside independent consultants, mediators or experts assisting counsel for the parties in this action (including potential experts). However, no Confidential discovery material shall be disseminated to any expert who is employed or retained by a direct business competitor of a party or its affiliates;
d. Authors of the Confidential discovery material and any person to whom the material was addressed;
e. Mediators appointed by the Court or hired by the parties in this action;
f. Actual or potential deponents or trial witnesses in this action, and their counsel, to the extent necessary to prepare for deposition or trial testimony in this action, witness shall maintain a written record of each person to whom Confidential discovery material was disclosed pursuant to this provision, and evidence that the person agreed in writing, in the format attached hereto as Exhibit "A", to be bound by this Stipulation and Order in connection with the Confidential discovery material, and that the producing party shall be entitled to review that record of Confidential discovery material disclosures upon a showing to the court of a need for such information; and g. The parties.

         4. Documents and testimony designated as Confidential shall be copied only by attorneys of record in this action, clerical personnel employed by such attorneys, or independent copying services engaged by such attorneys, provided that the attorney engaging a copying service has no reason to believe that that service or any of its employees is likely to ...

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