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Olympic Air, Inc. v. Helicopter Technology Co.

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

October 2, 2019

OLYMPIC AIR, INC. and CATLIN INSURANCE COMPANY, INC., Plaintiffs,
v.
HELICOPTER TECHNOLOGY COMPANY, Limited Partnership, a Nevada Limited Partnership; HELICOPTER TECHNOLOGY CORPORATION, a California corporation, General Partner for HELICOPTER TECHNOLOGY COMPANY, Limited Partnership; HELICOPTER TECHNOLOGY COMPANY, LLC, a foreign limited liability company and/or d/b/a of HELICOPTER TECHNOLOGY COMPANY, Limited Partnership; and MD HELICOPTERS, INC., an Arizona corporation, and DOES 1 through 10, Defendants. WILLIAM G. REED and MARY E. REED, husband and wife, and the marital community composed thereof, Plaintiffs,
v.
HELICOPTER TECHNOLOGY COMPANY, Limited Partnership, a Nevada Limited Partnership; HELICOPTER TECHNOLOGY CORPORATION, a California corporation, General Partner for HELICOPTER TECHNOLOGY COMPANY, Limited Partnership; HELICOPTER TECHNOLOGY COMPANY, LLC, a foreign limited liability company and/or d/b/a of HELICOPTER TECHNOLOGY COMPANY, Limited Partnership; and MD HELICOPTERS, INC., an Arizona corporation, and JOHN DOES 1 through 10, Defendants.

          STIPULATED PROTECTIVE ORDER

          HONORABLE ROBERT S. LASNIK United States District Judge

         1. PURPOSES AND LIMITATIONS

         Discovery in this action will involve production of confidential, proprietary, or private information for which special protection may be warranted. Accordingly, the parties hereby stipulate to and petition this 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, but not necessary; the following documents and tangible things produced or otherwise exchanged: Any information, material or document a person or entity in good faith believes constitutes or reveals (1) a trade secret or other confidential research, development, financial, proprietary, or commercial information, (2) a person's medical records, (3) a person's confidential employment records, (4) any information copied or extracted from confident!! material; (5) all copies, excerpts, summaries, or compilations of confidential material; and (6) an testimony, conversations, or presentations by parties or their counsel that might reveal confident material. However, the protections conferred by this agreement do not cover information that is in th public domain or becomes part of the public domain through trial or otherwise.

         3. ACCESS TO AND USE OF CONFIDENTIAL MATERIAL

         3.1 Basic Principles. A receiving party may use confidential material that is disclosed o: 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 musi be stored and maintained by a receiving party at a location and in a secure manner that ensures thai access is limited to the persons authorized under this agreement.

         3-2 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 and independent contractor attorneys and office staff 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 to Be Bound" (Exhibit A);
(d) the court, court personnel, and court reporters and their staff;
(e) copy or imaging services retained by counsel to assist in the duplication of confidential material, provided that counsel for the party retaining the copy or imaging service instructs the service not to disclose any confidential material to third parties and to immediately return all originals and copies of any confidential material;
(f) during their depositions, witnesses in the action to whom disclosure is reasonably necessary and who have signed the "Acknowledgment and Agreement to Be Bound" (Exhibit A), unless otherwise agreed by the designating party or ordered by the court. Pages of transcribed deposition testimony or exhibits to depositions that reveal confidential material must be separately bound by the court reporter and may not be disclosed to anyone except as permitted under this agreement;
(g) the author or recipient of a document containing the information or a custodian or other person who otherwise ...

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