United States District Court, W.D. Washington, Seattle
MODIFIED MODEL PROTECTIVE ORDER
S. ZILLY UNITED STATES DISTRICT JUDGE.
PURPOSES AND LIMITATIONS
to the Minute Order entered November 7, 2019, docket no. 28,
the Court enters this Protective Order, which tracks the
district's model form, but adds a provision permitting
the parties to designate materials as “Attorney's
Eyes Only.” This Protective Order 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” or
“Attorney's Eyes Only” information under
and tangible things produced in discovery may be designated
as “confidential” or “Attorney's Eyes
Only, ” as appropriate.
protections conferred by this Protective Order 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.
the protections conferred by this Protective Order do not
cover information that is in the public domain or becomes
part of the public domain through trial or otherwise.
ACCESS TO AND USE OF CONFIDENTIAL MATERIAL
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 Protective Order.
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 Protective Order.
Disclosure of “CONFIDENTIAL” Information or
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 information for this
(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
particular document or material produced is designated for
“Attorney's Eyes Only”;
(c) experts and consultants to whom disclosure is reasonably
necessary for this litigation and who have signed the
“Acknowledgment and Agreement ...