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Shattuck v. Fred Meyer Stores, Inc.

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

January 3, 2020

JANE SHATTUCK, a single individual, Plaintiff,
v.
FRED MEYER STORES, INC., and UNITED FOOD AND COMMERCIAL WORKERS, LOCAL 21, Defendants.

          Rodney R. Moody, WSBA #17416 Law Office of Rodney R. Moody Attorney for Plaintiff JANE SHATTUCK

          Ryan P. Hammond, WSBA #38888, Alyesha Asghar Dotson, WSBA #55122 LITTLER MENDELSON, P.C. Attorneys for Defendant FRED MEYER STORES, INC.

          Aaron Streepy, WSBA #38149 James G. McGuinness, WSBA #23494 Streepy Law PLLC Attorneys for Defendant UFCW Local No. 21

          STIPULATED PROTECTIVE ORDER

          Marsha J. Pechman United States 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: information regarding the personal, private, or financial information of Defendants Fred Meyer Stores, Inc. (referred to herein as “Defendant Fred Meyer”), and United Food and Commercial Workers Union, Local 21 (referred to herein as “Defendant United Food”) (collectively referred to herein as “Defendants”) current or former employees, including but not limited to birth dates, social security numbers, personal contact information, compensation information, performance evaluations (whether formal or informal), and disciplinary documents or history; any of Defendants' documents or information regarding accommodations, modified duties, leaves of absence, or compensation; and confidential or sensitive proprietary, commercial, or business information of a non-public nature that could injure Defendants if disseminated to the public or its competitors.

         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, or presentations by parties or their counsel that might reveal confidential material.

         However, the protections conferred by this agreement do not cover information that is in the public domain or becomes part of the public domain through trial or otherwise.

         4. ACCESS TO AND USE OF CONFIDENTIAL MATERIAL

         4.1 Basic Principles. A 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 agreement. 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 agreement.

         4.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless 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 ...

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