United States District Court, W.D. Washington, Seattle
SEA LEGAL PLLC Benjamin A. Ellison Attorneys for
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
S. LASNIK U.S. DISTRICT JUDGE.
PURPOSES AND LIMITATIONS
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.
material shall include the following documents and tangible
things produced or otherwise exchanged:
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.
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.
communications specifically identified by a party-in-interest
as potential attorney-client privileged communications.
communications specifically identified as potentially
embarrassing to a party.
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,