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Haram Corp. v. United States

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

September 25, 2019

HARAM CORPORATION, a Washington for profit Corporation, d/b/a DREXEL DELI & GROCERY et al., Plaintiffs,
v.
UNITED STATES OF AMERICA, Defendant.

          Andrew Tapp Attorney for Plaintiffs

          Ashley C. Burns, NY Bar #5186382 Attorney for Defendant

          ORDER

          JOHN C. COUGHENOUR UNITED STATES DISTRICT JUDGE

         Pursuant to the parties’ stipulation and proposed amended protective order (Dkt. No. 22) the Court hereby ENTERS the following amended protective order:

         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 Western District of Washington 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 the parties to file confidential information under seal.

         2. “CONFIDENTIAL” MATERIAL

         “Confidential” material shall include the following documents and tangible things produced or otherwise exchanged:

(a) Applicable portions of the administrative record containing information exempt from disclosure under the Food and Nutrition Act of 2008;
(b) Governmental records containing information exempt from disclosure under the Food and Nutrition Act of 2008;
(c) Applicable portions of records prepared in relation to the USDA investigation of Plaintiff containing information exempt from disclosure under the Food and Nutrition Act of 2008;
(d) Portions of deposition transcripts containing information exempt from disclosure under the Food and Nutrition Act of 2008;
(e) Any financial information not publicly filed with any federal or state regulatory authority;
(f) Information pertaining to SNAP households, including but not limited to the household’s SNAP card number, demographic information, household size, and names of authorized users in the household;
(g) Comparison store information, including sales data, inventory records, operational details and other identifying information; and
(h) Information pertaining to FNS policies and procedures and ALERT operational information whose dissemination would compromise the ability of the USDA to discover illegal EBT activity and allow retailers to avoid detection, including but not limited to policy memoranda, pertinent portions of the Standard Operating Procedures, and other program details, guidelines, thresholds or information.

         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 ...


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