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Lillywhite v. AECOM

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

December 30, 2019

ERIC LILLYWHITE, Plaintiff,
v.
AECOM et al., Defendants.

          ORDER

          JOHN C. COUGHENOUR UNITED STATES DISTRICT JUDGE

         This matter comes before the Court on the parties' stipulated motion for entry of a protective order (Dkt. No. 33). The Court hereby GRANTS the motion and ENTERS the following protective order:

         1. Discovery in this action is likely to involve production of confidential, statutorily protected, or private information, or other material that is exempt from public disclosure or for which special protection may be warranted. This agreement is consistent with Western District of Washington Local Civil Rule 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. This order shall be applicable to and govern all depositions, documents, information, or things produced with initial disclosures and/or in response to requests for production of documents, answers to interrogatories, responses to requests for admissions, and all other discovery taken under the Federal Rules of Civil Procedure and the Local Civil Rules for the Western District of Washington, and other information which the producing party designates as “CONFIDENTIAL, ” hereinafter furnished, directly or indirectly, by or on behalf of any party or any non-party in connection with this action.

         3. The following information may be designated as CONFIDENTIAL: employment, personnel, health, financial, regulatory and private information about Plaintiff, Defendants, current and former employees of any defendant, or third parties that is not publicly available.

         4. Parties shall designate records as confidential information by labeling them as CONFIDENTIAL prior to production. Deposition or other pretrial or trial testimony meeting the criteria specified in paragraph 3 above may be designated CONFIDENTIAL by a statement on the record by counsel during such deposition or other pretrial or trial proceeding that the entire transcript or a portion thereof shall be designated as CONFIDENTIAL. Only those portions or excerpts of a deposition consisting of confidential material shall be designated as CONFIDENTIAL. Deposition or other pretrial testimony meeting the criteria specified in paragraph 3 above also may be designated as CONFIDENTIAL by stamping a CONFIDENTIAL legend on the transcript of such testimony and serving copies on the other parties within 30 days after the transcript is received by the designating party, regardless of whether any confidentiality designation was made on the record at the time the testimony was given.

         5. A CONFIDENTIAL designation by a party shall be made in good faith.

         6. A party shall not be obligated to challenge the propriety of a CONFIDENTIAL designation at the time made, and failure to do so shall not preclude subsequent challenge thereto. Failure to challenge the propriety of any CONFIDENTIAL designation shall not constitute an admission as to the propriety of that designation.

         7. Counsel for such parties shall make a good faith effort to confer to resolve by agreement any differences as to the use or designation of information as CONFIDENTIAL prior to bringing the issue to the Court.

         8. All documents and testimony designated as CONFIDENTIAL, and all information derived solely therefrom, if not available in any other source, shall be used solely for the purpose of preparing and litigating claims in this lawsuit, shall not be disclosed, published in any medium by any party, or disseminated except as provided for in Paragraph 9 below. Any use of documents and testimony designated as CONFIDENTIAL, and all information derived solely therefrom, that is inconsistent with this order shall be a breach of its terms.

         9. Except as may be otherwise agreed by the parties, or ordered by the Court, disclosure of documents and testimony designated as CONFIDENTIAL, and all information derived therefrom, shall be limited to:

(a) A party, or an employee of a party to whom it is necessary that the information be shown for purposes of preparing or litigating this lawsuit;
(b) Counsel for a party, or an employee of counsel for a party to whom it is necessary that the information be shown for purposes of preparing or litigating this lawsuit, such as any paralegal assistants, or other support staff assisting counsel in the preparation of this lawsuit;
(c) An expert, consultant, or third party consulted or retained by a party or such party's counsel to assist in ...

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