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BGH Holdings, LLC v. DL Evans Bank

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

October 3, 2019

BGH HOLDINGS, LLC, a Washington limited liability company; GINGER ATHERTON; HENRY DEAN, and their marital community, Plaintiffs,
v.
DL EVANS BANK, Defendant.

          Dennis J. McGlothin, Attorneys for Plaintiffs Henry Dean, Ginger Atherton, BGH Holdings LLC, and Additional parties James Dean, Frank Dean and WN3, LLC.

          Rhys M. Farren, Attorneys for Defendant.

          STIPULATED PROTECTIVE ORDER

          Robert S. Lasnik, United States District Judge.

         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 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 the following documents and tangible things produced or otherwise exchanged and interrogatory answers/responses that contain:

A. Tax returns;
B. Customer list or customer information;
C. Financial account statements;
D. Documents and interrogatory answers that contain or disclose personal identifying information such as financial account numbers, social security numbers or federal employment identification numbers (“Personal Identifying Information”);
E. Health care records;
F. Patents, patent applications and the processes or ideas that are being or have been patented;
G. The technology HTP, Inc. is using in its business;
H. shareholders', option holders', officers', directors', agent's or employees' Personal Identifying Information.
I. Bank proprietary processes, customer information or audit or regulatory 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 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” ...


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