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Reed v. General Mills, Inc.

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

September 10, 2019

BRUCH REED, et al., Plaintiffs,
v.
GENERAL MILLS, INC., et al., Defendants.

          Stephen M. Raab, Gutride Safier LLP Marie A. McCrary, Esq., pro hac vice Gutride Safier LLP Attorneys for Plaintiffs.

          Charles C. Sipos, Lauren Watts Staniar, Mica Klein, Perkins Coie LLP David T. Biderman, pro hac vice Perkins Coie LLP Attorneys for Defendants General Mills, Inc. and Small Planet Foods, Inc.

          ORDER

          JOHN C. COUGHENOUR UNITED STATES DISTRICT JUDGE.

         This matter comes before the Court on the parties' stipulated protective order (Dkt. No. 43). The Court ENTERS the following:

         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 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.

         2. DEFINITIONS

         2.1 “CONFIDENTIAL” Information or Items.

         “Confidential” material may include the following documents and tangible things produced or otherwise exchanged: (1) Plaintiffs' personal information (including, but not limited to, social security numbers, credit card numbers, account numbers, and health information); (2) drafts of advertisements; (3) drafts of marketing material; (4) drafts of product packaging and/or labels; (5) organizational charts, including, but not limited to, information reflecting any relationship between General Mills, Inc. and Small Planet Foods; (6) any agreements between General Mills, Inc. and/or Small Planet Foods, Inc. and any third-party; (7) communications between General Mills, Inc. and/or Small Planet Foods, Inc., and any federal or state regulatory agency regarding the Cascadian Farm-branded products; (8) documents or communications relating to the agricultural output of the Home Farm; and (9) any information (regardless of how it is generated, stored, or maintained) or tangible things that qualify for protection under Federal Rule of Civil Procedure 26(c).

         2.2 “HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY” Information or Items.

         “Highly Confidential - Attorneys' Eyes Only” material may include: (1) trade secrets; (2) pricing lists; (3) financial information (including, but not limited to, documents or communications regarding sales and/or profits); (4) lists of retailers and/or wholesalers; (5) customer lists; (6) consumer inquires and/or complaints; (7) personal information of any General Mills, Inc. or Small Planet Foods, Inc. employee or contractor (including, but not limited to, social security numbers, credit card numbers, and account numbers); (8) consumer research; (9) documents reflecting marketing and/or sales strategy (including any internal memoranda relating to any marketing or sales material or campaign); (9) documents relating to the source of ingredients in Cascadian Farm-branded products; (10) marketing research; (11) board meetings or minutes of board meetings; (12) internal documents or communications relating to any law or standard that governs the labels of the Cascadian Farm-branded products; (13) communications discussing or describing such material; (14) and any other information the disclosure of which to another party or non-party would create a substantial risk of serious harm that could not be avoided by less restrictive means.

         2.3 Protected Material.

         Any discovery material that is designated as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY.”

         3. SCOPE

         The protections conferred by this agreement cover not only Protected 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 Protected Material that is disclosed or produced by another party or by a non-party in connection with the case captioned Reed, et al. v. General Mills, Inc., et al., No. 19-cv-00005 (W.D. Wash. 2019), only for prosecuting, defending, or attempting to settle this litigation. Protected Material may be disclosed only to the categories of persons and under the conditions described in this agreement. Protected 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 ...

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