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Wang v. Hull

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

December 12, 2019

ZHIZHENG WANG, for the WANG LENDER GROUP, Plaintiff,
v.
BRUCE HULL, an individual, Defendant. DECATHLON ALPHA III, L.P., Intervenor Plaintiff
v.
ZHIZHENG WANG, for the WANG LENDER GROUP Intervenor Defendant

          SALISH SEA LEGAL PLLC Benjamin A. Ellison Attorneys for Plaintiff's

          GORDON REES SCULLY MANSUKHANI, LLP Derek A. Bishop Sarah Turner Attorneys for Defendant Bruce Hull

          SCHWABE, WILLIAMSON & WYATT, P.C. Jennifer Campbel Farron Curry Attorneys for Intervenor Decathlon Alpha III, L.P.

          FREDRIKSON & BYRON, P.A. Kevin C. Riach Pro Hac Vice Attorney for Intervenor Decathlon Alpha III, L.P.

          STIPULATED PROTECTIVE ORDER

          ROBERT S. LASNIK U.S. 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:

         2.1 Any and all financial information, banking information, tax returns and/or information contained therein, profit and loss statements or any other financial information which is not already in the public domain.

         2.2 Any and all personal information including, but not limited to individual's addresses, phone numbers, e-mail addresses or other contact information, payroll information, rate of pay, disciplinary history; work history, family information, financial information which is not already in the public domain, social security numbers, or dates of birth, or any other private information which may be obtained through discovery. Unredacted e-mails shall not be considered confidential as a whole merely because of the presence of e-mail addresses indicated on them.

         2.3 All communications specifically identified by a party-in-interest as potential attorney-client privileged communications.

         2.4 All communications specifically identified as potentially embarrassing to a party.

         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, ...


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