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Roush v. Akal Group of Companies, LLC

United States District Court, E.D. Washington

November 4, 2019

RONALD W. ROUSH and JAMES H. HUNTER, Plaintiffs,
v.
AKAL GROUP OF COMPANIES, LLC, d/b/a Akal Security, Inc., Defendant.

          PROTECTIVE ORDER

          JOHN T. RODGERS, UNITED STATES MAGISTRATE JUDGE

         Pursuant to Rule 26(c) of the Federal Rules of Civil Procedure, it is hereby ordered as follows:

         1. This “Protective Order” (“Order”) shall govern all discovery materials (including testimony, interrogatories, responses, documents, writings, drawings, graphs, charts, photographs, and electronic materials) believed to contain confidential and/or proprietary information (referred to as “Confidential Material”) produced by Akal Security, Inc. (referred to herein as “Akal”). “Confidential Material” shall include, but not be limited to, all financial information and data and testimony regarding, related to or in any way connected with Akal, or any of its affiliated companies, firms, partnerships, associations or corporations, and personnel information regarding non-parties.

         2. Documents and things deemed by Akal to be “Confidential Material” shall be Bates-stamped with a designation of “C” preceding the Bates number or stamped “Confidential” so as to clearly indicate their status as “Confidential Material” documents. Testimony deemed by Akal to be “Confidential Material” shall be so designated on the record of such testimony. Documents that contain a mix of relevant and irrelevant information shall be redacted to protect the irrelevant information.

         3. All information, testimony and documents deemed “Confidential Material” shall be used solely in connection with, and for the exclusive purpose of, pre-trial proceedings, preparation for trial, trial or other proceedings in this litigation only, and not for any other purpose. “Confidential Material” shall not be divulged or disclosed to anyone or to any entity other than “Qualified Persons” (as defined in Paragraph 4 of this “Order”) and “Additional Persons” who have satisfied the prerequisites to receive “Confidential Material” (said prerequisites being contained in Paragraph 6 of this “Order”).

         4. “Confidential Material” and documents and any copies thereof, and notes made therefrom, shall be disclosed only to “Qualified Persons.” “Qualified Persons” are limited to:

a. the parties to this lawsuit;
b. the parties' counsel of record and the paralegals and clerical staff employed by the parties' counsel of record for the preparation of and/or trial of this action;
c. the parties to this lawsuit's expert witnesses (if any); and
d. this Court and all of this Court's personnel, including court reporters, in the conduct of their official duties.

         5. Plaintiffs Ronald W. Roush and James H. Hunter must, within ten (10) days of this Order, circulate non-work physical and e-mail addresses to counsel for Akal for transmission of any information related to this lawsuit. If Plaintiffs do not provide such addresses, Akal may produce documents to the Clerk of the Court for Plaintiffs to physically retrieve from the courthouse.

         6. Further, Plaintiffs are not permitted to maintain any documents relative to this lawsuit on their work computers, in their work e-mail accounts, and on their work servers, electronic storage (e.g. Cloud, Dropbox, etc.), hard drives, flash drives, or similar data storage device or mechanism.

         7. Plaintiffs Ronald W. Roush and James H. Hunter shall keep all “Confidential Material” confidential, and they shall not provide, publish or communicate the “Confidential Material” in any manner or medium to anyone other than “Qualified Persons” or “Additional Persons.” If Plaintiffs, or either of them, fail to abide by the terms of the Court's “Protective Order, ” the Court may impose sanctions, including sanctions by way of contempt of court, for such a failure. If Plaintiffs desire to provide “Confidential Material” to anyone other than “Qualified Persons” (who are referred to in this document as “Additional Person(s)”), then counsel for Akal shall be provided five (5) business days prior notice of: (i) Plaintiffs' intent to provide such “Confidential Material” to the “Additional Person(s), ” (ii) the name, address and telephone number of the “Additional Person(s), ” and (iii) a copy of a “Written Assurance” in the form of Exhibit “A, ” attached hereto, that has been executed by the “Additional Person(s), ” without changes. If counsel for Akal serves an objection with the Court within that five (5) day period, then such “Confidential Material” shall not be disclosed, divulged or provided to the “Additional Person(s)” unless and until authorized by the Court. If Akal does not object to the production of the “Confidential Material” to the “Additional Person(s), ” or if the Court rules that such “Confidential Material” is to be provided to the “Additional Person(s), ” then the executed “Written Assurance” of the “Additional Person(s)” shall be immediately filed with the Clerk of the United States District Court for the Eastern District of Washington, by Plaintiffs and served upon counsel for Akal.

         8. This “Order” prohibits the disclosure of “Confidential Material” and prohibits the discussion of such “Confidential Material” with any person to whom disclosure is ...


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