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Schneider v. The Ultimate Software Group Inc.

United States District Court, W.D. Washington

July 10, 2019

JEREMY SCHNEIDER, an individual, Plaintiff,
THE ULTIMATE SOFTWARE GROUP, INC., a Delaware corporation, Defendant.

          VANGUARD LAW, LLC Spencer Nathan Thal, WSBA #20074 Vanguard Law, LLC PO Box 939 Attorney for Plaintiff

          OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C. Jaime N. Cole, WSBA# 47258 Anthony B. Byergo, WSBA #50929 Attorneys for Defendant




         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.


         “Confidential” material shall mean any information that is non-public information of Defendant, and anything which by virtue of its nature would naturally be considered to be confidential information of Defendant, in any form, manner or media, including but not limited to Defendant's business, operations and plans, its processes, source codes, trade secrets, customer lists, prospective customer lists, names, personal information and data of any other kind of Defendant, Defendant's customers, and Defendant's prospective customers, and its and their employees, books, charts, records, documents, computer material or records, reports and surveys, past, current, future or proposed hardware or software products, components thereof or improvements thereto; business forecasts and procurement requirements of Defendant, marketing strategies, pricing, financial results, plans, requirements, processes and technology relating to the foregoing products, components or improvements, the research and development activities of Defendant, and computer programs, source code, data files, design, layout and associated documentation of Defendant. Confidential material shall also include any of the following information of either party that is marked or otherwise identified as confidential or proprietary, or that the other party knows or should know is confidential or proprietary and all (a) technical information including but not limited to patent, trade secret and proprietary information, techniques, sketches, drawings, models, inventions, know-how, processes, apparatus, equipment, source code and algorithms related to either party, and (b) information relating to costs, prices and names, finances, marketing plans, business opportunities, personnel, research, development or know-how and shall be treated as confidential. Finally, confidential material shall include any information and/or documentation related to nonparty employees of Defendant; Plaintiff's personnel related information/documentation; Plaintiff's medical records; and any documents that relate to Plaintiff's mental health or that contain Plaintiff's social security number.

         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.


         4.1 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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