Phillip Morris Jr. v. James Tilton et al

Filing 202

PROTECTIVE ORDER by Magistrate Judge Suzanne H. Segal re Stipulation for Protective Order 201 ; See order for details. (jy)

1 LATHAM & WATKINS LLP
David J. Schindler (Bar No. 130490)
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[e-mail]
Marie M. Dalton (Bar No. 246606)
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[e-mail]
David Yaroslavsky (Bar No. 255574)
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[e-mail]
355 South Grand Avenue
5 Los Angeles, California 90071-1560
Telephone: [phone]
6 Facsimile: [phone]
Attorneys for Plaintiff Phillip Morris, Jr.
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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA

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CV 08-2823-VBF (SS)

PHILLIP MORRIS, JR.,

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Plaintiff,

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vs.

[PROPOSED] PROTECTIVE
ORDER

14 R. A. WHITE, et al.,
Defendants.
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[Stipulation for Protective Order Filed
Concurrently Herewith]

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Courtroom:
Magistrate Judge:

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23 – 3rd Floor
The Honorable
Suzanne H. Segal

Hearing: N/A

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LA\2465277.1

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[PROPOSED] PROTECTIVE ORDER
CASE NO. CV 08-2823-VBF (SS)

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ORDER

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Based on the stipulation of the parties filed concurrently herewith, and for
good cause shown, the Court makes the following orders:

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1.

Confidential Reports produced in discovery by Defendants for “Attorney’s Eyes
Only.” Specifically, Plaintiff’s counsel shall take all reasonable steps to safeguard
the Confidential Reports, and shall not disclose or disseminate the documents or
their content except as provided herein. Plaintiff’s counsel will not disseminate or
disclose the contents of the Reports to Plaintiff Phillip Morris, Jr. or third-parties,
without first obtaining the consent of Defendants’ counsel or a court order
authorizing such disclosure. Plaintiff’s counsel, however, may share such
information with experts, contractors, and investigators retained by the Plaintiff
without obtaining further consent provided that such individual(s) are provided
with a copy of this order and consent to be bound by its terms to the same extent as
Plaintiff’s counsel.

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2.

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Plaintiff’s counsel shall not use the Confidential Reports for any other

reason than preparing for trial in this case.

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Plaintiff’s counsel shall maintain the confidentiality of the

3.

Plaintiff’s counsel shall return the Confidential Reports, and any and

all copies of the Confidential Reports, to Defendants’ counsel at the conclusions of
the proceedings in this case, including any appeal, or as soon as a mutually
agreeable method for production is arranged by the Parties.
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LA\2465277.1

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[PROPOSED] PROTECTIVE ORDER
CASE NO. CV 08-2823-VBF (SS)

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4.

This Protective Order, and the obligations of all persons thereunder,

2 including those related to disclosure and use of the Confidential Reports, shall
3 survive the final termination of this case, whether such termination is by
4 settlement, judgment, dismissal, appeal, or otherwise, until further order of this
5 Court.
6 IT IS SO ORDERED.
_____/S/_________
Hon. Suzanne H. Segal
United States Magistrate Judge

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February 17, 2012

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LA\2465277.1

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[PROPOSED] PROTECTIVE ORDER
CASE NO. CV 08-2823-VBF (SS)