Loren Stone v. Howard Johnson International, Inc. et al
Filing
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PROTECTIVE ORDER by Magistrate Judge Margaret A. Nagle re Stipulation for Protective Order 27 (ec)
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NANCY L. STAGG CA Bar No. 157034
nstagg@foley.com
Foley & Lardner LLP
402 WEST BROADWAY, SUITE 2100
SAN DIEGO, CA 92101-3542
TELEPHONE:
619.685.6454
FACSIMILE:
619.234.3510
ANDREW B. SERWIN CA Bar No. 179493
aserwin@foley.com
TAMMY H. BOGGS CA Bar No. 252538
tboggs@foley.com
Foley & Lardner LLP
3579 VALLEY CENTRE DRIVE, SUITE 300
SAN DIEGO, CA 92130-3302
TELEPHONE:
858.847.6700
FACSIMILE:
858.792.6773
Attorneys for Defendant,
HOWARD JOHNSON INTERNATIONAL, INC.
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UNITED STATES DISTRICT COURT
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CENTRAL DISTRICT OF CALIFORNIA – WESTERN DIVISION
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Case No. 12-CV-1684-PSG (MANx)
LOREN STONE, individually and on
behalf of all others similarly situated,
PROTECTIVE ORDER ENTERED
PURSUANT TO THE PARTIES’
STIPULATION
Plaintiff,
v.
HOWARD JOHNSON
INTERNATIONAL, INC., a Delaware
Corporation; and DOES 1 – 10,
Defendants.
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Pursuant to Rule 26(c) of the Federal Rules of Civil Procedure and based on
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the parties’ Stipulation and [Proposed] Protective Order Governing the Pre-Trial
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Handling of Confidential Information (“Stipulation”) filed on December 10, 2012, the
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terms of the protective order to which the parties have agreed are adopted as a
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protective order of this Court (which generally shall govern the pretrial phase of this
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action) except to the extent, as set forth below, that those terms have been
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substantively modified by the Court’s amendment of paragraphs 1, 2.6(f), 2.7, 4.3(b),
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5, and 9 of the Stipulation.
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The parties are expressly cautioned that the designation of any information,
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document, or thing as “Confidential,” “Highly Confidential – Attorney’s Eyes Only,”
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or other designation(s) used by the parties, does not, in and of itself, create any
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entitlement to file such information, document, or thing, in whole or in part, under
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seal. Accordingly, reference to this Protective Order or to the parties’ designation of
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any information, document, or thing as “Confidential,” “Highly Confidential –
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Attorney’s Eyes Only,” or other designation(s) used by the parties, is wholly
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insufficient to warrant a filing under seal.
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There is a strong presumption that the public has a right of access to judicial
proceedings and records in civil cases. In connection with non-dispositive motions,
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good cause must be shown to support a filing under seal. The parties’ mere
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designation of any information, document, or thing as “Confidential,” “Highly
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Confidential – Attorney’s Eyes Only,” or other designation(s) used by parties, does
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not -- without the submission of competent evidence, in the form of a declaration
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or declarations, establishing that the material sought to be filed under seal
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qualifies as confidential, privileged, or otherwise protectable -- constitute good
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cause.
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Further, if sealing is requested in connection with a dispositive motion or trial,
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then compelling reasons, as opposed to good cause, for the sealing must be shown,
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and the relief sought shall be narrowly tailored to serve the specific interest to be
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protected. See Pintos v. Pacific Creditors Ass’n, 605 F.3d 665, 677-79 (9th Cir.
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2010). For each item or type of information, document, or thing sought to be filed or
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introduced under seal in connection with a dispositive motion or trial, the party
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seeking protection must articulate compelling reasons, supported by specific facts and
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legal justification, for the requested sealing order. Again, competent evidence
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supporting the application to file documents under seal must be provided by
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declaration.
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Any document that is not confidential, privileged, or otherwise protectable in
its entirety will not be filed under seal if the confidential portions can be redacted. If
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documents can be redacted, then a redacted version for public viewing, omitting only
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the confidential, privileged, or otherwise protectable portions of the document, shall
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be filed. Any application that seeks to file documents under seal in their entirety
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should include an explanation of why redaction is not feasible.
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Notwithstanding any other provision of this Protective Order, in the event that this
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case proceeds to trial, all information, documents, and things discussed or introduced
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into evidence at trial will become public and available to all members of the public,
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including the press, unless sufficient cause is shown in advance of trial to proceed
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otherwise.
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TERMS OF PROTECTIVE ORDER
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1.
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This Protective Order and the Parties’ stipulation upon which it is based does
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GENERAL LIMITATION
not change, amend, or circumvent any court rule or local rule governing this action.
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2.
DEFINITIONS
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2.1
Party: Any party to this action, including all of its officers, directors,
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employees, consultants, and agents.
2.2
Disclosure or Discovery Material: All items or information, regardless
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of the medium or manner generated, stored, or maintained (including, among other
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things, testimony, transcripts, or tangible things) that are produced or generated in
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disclosures or responses to discovery in this matter.
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2.3
“Confidential” Information or Items: In connection with discovery
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proceedings in this action, the Parties may designate any document, thing, material,
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testimony, video or audio recording, or other information derived therefrom, as
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“CONFIDENTIAL” (hereinafter – “Confidential”) under the terms of this Protective
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Order only if, in the good faith belief of such Party and its counsel, the unrestricted
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disclosure of information could be prejudicial to the business, operations, or privacy
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interests of such Party or of non-parties. “Confidential” information as used herein
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means any information that a party in good faith believes constitutes or reveals
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proprietary or commercially sensitive information, trade secrets, information subject
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to a legally protected right of privacy, personal identifying information, personal
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financial information, or other information subject to protection under the law. By
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designating a document, thing, material, testimony, video or audio recording, or other
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information derived therefrom as “Confidential” under the terms of this Protective
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Order, the Party making the designation is certifying to the Court that there is a good
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faith basis both in law and in fact for the designation within the meaning of Federal
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Rule of Civil Procedure 26(g).
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2.4
“Highly Confidential–Attorney’s Eyes Only” Information or Items: In
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connection with discovery proceedings in this action, the Parties may designate any
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document, thing, material, testimony, video or audio recording, or other information
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derived therefrom, as “HIGHLY CONFIDENTIAL – ATTORNEY’S EYES ONLY”
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(hereinafter – “Attorney’s Eyes Only”) under the terms of this Protective Order only
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if, in the good faith belief of such Party and its counsel, the information is among that
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considered to be most sensitive by the Party and its disclosure to another Party or
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non-party would create a substantial risk of serious injury that could not be avoided
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by less restrictive means. This information includes but is not limited to trade secret
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or other highly confidential financial, commercial, personal, or private information.
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Attorney’s Eyes Only material, and the information contained therein, shall be
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disclosed only to the Court, to counsel for the Parties (including their support staff),
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and to the “qualified persons” defined in Section 2.6 below, subparts (b)–(f), but shall
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not be disclosed to a Party (as defined herein at Section 2.1), unless otherwise agreed
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to or ordered. If disclosure of “Attorney’s Eyes Only” material is made pursuant to
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this paragraph, all other provisions in this Protective Order with respect to
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confidentiality shall also apply.
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2.5
Protected Material: Any Disclosure or Discovery Material that is
designated as “Confidential” or as “Highly Confidential–Attorney’s Eyes Only.”
2.6
Qualified Persons: Protected Material produced pursuant to this
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Protective Order may be disclosed or made available only to the Court, to counsel for
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a Party (including attorney support staff), and to the following “qualified persons”
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designated below:
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(a) a Party or officer, director, agent, or employee of a Party deemed
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necessary by counsel to aid in the prosecution, defense, or settlement of this action;
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(b) Experts or consultants (together with their clerical staff), as defined
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in section 2.10 below, retained by such counsel to assist in the prosecution, defense,
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or settlement of this action;
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(c) Professional vendor(s), as defined in section 2.11 below, employed in
this action;
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(d) a witness at any deposition or other proceeding in this action;
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(e) the author of the document or the original source of the information;
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and
(f) any other person as to whom the Parties in writing agree.
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Prior to receiving any Protected Material, each “qualified person,” with the
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exception of Outside Counsel for a Party and the Court, shall be provided with a
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copy of this Protective Order and shall execute a nondisclosure agreement in the form
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of Exhibit A, a copy of which shall be maintained by counsel who is providing access
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to the Protected Material. Upon request of a Party, the counsel providing access to
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the Protected Materials shall provide a copy of the executed nondisclosure agreement
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to counsel for the requesting Party, but only after the individual who received the
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Protected Materials has been identified through the normal course of discovery.
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2.7(a) Designating Party: A Party or non-party that designates information or
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items that it produces in disclosures or in responses to discovery as “Confidential” or
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“Highly Confidential–Attorney’s Eyes Only.”
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(b)Receiving Party: A Party that receives information or items
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produced by a Designating Party in disclosures or in responses to discovery that
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have been designated as “Confidential” or “Highly Confidential–Attorney’s
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Eyes Only.”
2.8
Outside Counsel: Attorneys who are not employees of a Party but who
are retained to represent or advise a Party in this action, including their support staff.
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2.9
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2.10 Expert: A person with specialized knowledge or experience in a matter
House Counsel: Attorneys who are employees of a Party.
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pertinent to the litigation who has been retained by a Party or its counsel to serve as
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an expert witness or as a consultant in this action and who is not a current employee
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of a competitor of a Party and who, at the time of retention, is not anticipated to
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become an employee of a competitor of a Party. This definition includes a
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professional jury or trial consultant retained in connection with this litigation.
2.11 Professional Vendors: Persons or entities that provide litigation support
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services (e.g., photocopying; videotaping; translating; preparing exhibits or
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demonstrations; organizing, storing, or retrieving data in any form or medium; etc.)
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and their employees and subcontractors.
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3.
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Material designated as “Confidential” or “Attorney’s Eyes Only” material
SCOPE
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under this Protective Order, the information contained therein, and any summaries,
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copies, abstracts, or other documents derived in whole or in part from material
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designated as confidential, shall be used only for the purpose of the prosecution,
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defense, and settlement of this action, and for no other purpose. However, the
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restrictions and obligations set forth within this Protective Order will not apply to any
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information that: (a) the Parties agree should not be designated as Protected Material;
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(b) the Parties agree, or the Court rules, is already public knowledge; (c) the Parties
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agree, or the Court rules, has become public knowledge other than as a result of
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disclosure by the Receiving Party, its employees, or its agents in violation of this
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Protective Order; or (d) has come into the Receiving Party’s legitimate knowledge
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independently of the production by the Designating Party. Prior knowledge must be
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established by pre-production documentation.
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4.
DESIGNATING PROTECTED MATERIAL
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4.1
Confidential documents shall be so designated by stamping copies of the
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document produced to a Party with the legend “CONFIDENTIAL” on each
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document or on each page of a multi-page document and for protection under this
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Protective Order must be clearly so designated before the material is disclosed or
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produced.
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4.2
Attorney’s Eyes Only material shall be similarly designated by stamping
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copies of the document produced to a Party’s outside counsel with the legend
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“HIGHLY CONFIDENTIAL –ATTORNEY’S EYES ONLY” on each document or
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on each page of a multi-page document and for protection under this Protective Order
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must be clearly so designated before the material is disclosed or produced.
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4.3
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Designation in conformity with this Protective Order requires:
(a)
For information in documentary form (apart from transcripts of
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depositions or other pretrial or trial proceedings), that the Producing Party affix the
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legend “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL–ATTORNEY’S EYES
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ONLY” on each page that contains Protected Material. If only a portion or portions
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of the material on a page qualifies for protection, the Producing Party also must
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clearly identify the protected portion(s) (e.g., by making appropriate markings in the
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margins) and must specify, for each portion, the level of protection being asserted
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(either “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL–ATTORNEY’S EYES
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ONLY”).
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(b)
Testimony taken at a deposition may be designated as confidential
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by making a statement to that effect on the record at the deposition. Arrangements
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shall be made with the court reporting service taking and transcribing the deposition
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to bind separately such portions of the transcript containing information designated as
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“Confidential” or “Highly Confidential – Attorney’s Eyes Only,” as the case may be,
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and to label such portions appropriately. Depositions shall be taken only in the
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presence of qualified persons, as defined in Section 2.6 above. When it is impractical
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to identify separately each portion of testimony that is entitled to protection, and
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when it appears that substantial portions of the testimony may qualify for protection,
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the Party or non-party that sponsors, offers, or gives the testimony may invoke on the
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record (before the deposition is concluded) a right to have up to 20 days after delivery
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of the transcript to identify the specific portions of the testimony as to which
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protection is sought and to specify the level of protection being asserted
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(“CONFIDENTIAL” or “HIGHLY CONFIDENTIAL–ATTORNEY’S EYES
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ONLY”). Only those portions of the testimony that are appropriately designated for
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protection within the 20 days after delivery of the transcript shall be covered by the
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provisions of this Protective Order.
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(c)
For information produced in some form other than documentary
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form, and for any other tangible items, that the Producing Party affix in a prominent
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place on the exterior of the container or containers in which the information or item is
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stored the legend “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL–
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ATTORNEY’S EYES ONLY.” If only portions of the information or item warrant
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protection, the Producing Party, to the extent practicable, shall identify the protected
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portions, specifying whether they qualify as “Confidential” or as “Highly
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Confidential–Attorney’s Eyes Only.”
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4.4
Inadvertent Failures to Designate. If timely corrected, an inadvertent
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failure to designate qualified information or items as “Confidential” or “Highly
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Confidential–Attorney’s Eyes Only” does not, standing alone, waive the Designating
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Party’s right to secure protection under this Protective Order for such material. If
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material is appropriately designated as “Confidential” or “Highly Confidential–
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Attorney’s Eyes Only” after the material was initially produced, the Receiving Party,
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on timely notification of the designation, must make reasonable efforts to assure that
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the material is treated in accordance with the provisions of this Protective Order.
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5.
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This Protective Order shall be without prejudice to the right of the Parties to:
CHALLENGING CONFIDENTIALITY DESIGNATIONS
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(i) bring before the Court at any time the question of whether any particular document
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or information is confidential or whether its use should be restricted; or (ii) present a
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motion to the Court under Federal Rule of Civil Procedure Rule 26(c) for a separate
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protective order as to any particular document or information, including restrictions
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differing from those specified herein. This Protective Order shall not be deemed to
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prejudice the Parties in any way in the further application for modification of this
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Protective Order.
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A Party that elects to initiate a challenge to a Designating Party’s
confidentiality designation must do so in good faith and must begin the process by
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conferring directly (in voice-to-voice dialogue; other forms of communication are not
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sufficient) with counsel for the Designating Party. In conferring, the challenging
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Party must explain the basis for its belief that the confidentiality designation was not
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proper and must give the Designating Party an opportunity to review the designated
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material, to reconsider the circumstances, and, if no change in designation is offered,
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to explain the basis for the chosen designation. A challenging Party may only bring a
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confidentiality designation to the Court if it has engaged in this meet and confer
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process first. The burden of establishing that documents and/or materials have
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been properly designated shall be upon the Designating Party at all times.
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The Court may modify the terms and conditions of this Protective Order for
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good cause, or in the interests of justice, or on its own order, at any time in these
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proceedings.
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6.
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Protected Material must be stored and maintained by a Receiving Party at a
ACCESS TO AND USE OF PROTECTED MATERIAL
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location and in a secure manner that ensures that access is limited to the persons
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authorized under this Order.
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7.
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PROTECTED MATERIAL SUBPOENAED OR ORDERED
PRODUCED IN OTHER LITIGATION
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If a Receiving Party is served with a subpoena or an order issued in other
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litigation that would compel disclosure of any information or items designated in this
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action as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL–ATTORNEY’S
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EYES ONLY,” the Receiving Party must so notify the Designating Party, in writing
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(by fax, if possible) immediately and in no event more than three (3) court days after
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receiving the subpoena or order. Such notification must include a copy of the
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subpoena or court order.
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The Receiving Party also must immediately inform in writing the Party who
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caused the subpoena or order to issue in the other litigation that some or all the
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material covered by the subpoena or order is the subject of this Protective Order. In
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addition, the Receiving Party must deliver a copy of this Protective Order promptly to
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the Party in the other action that caused the subpoena or order to issue.
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The purpose of imposing these duties is to alert the interested parties to the
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existence of this Protective Order and to afford the Designating Party in this case an
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opportunity to try to protect its confidentiality interests in the court from which the
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subpoena or order issued. The Designating Party shall bear the burdens and the
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expenses of seeking protection in that court of its confidential material, and nothing
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in these provisions should be construed as authorizing or encouraging a Receiving
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Party in this action to disobey a lawful directive from another court.
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8.
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If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
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Protected Material to any person or in any circumstance not authorized under this
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Protective Order, the Receiving Party must immediately: (a) notify in writing the
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Designating Party of the unauthorized disclosures; (b) use its best efforts to retrieve
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all copies of the Protected Material; (c) inform the person or persons to whom
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unauthorized disclosures were made of all the terms of this Protective Order; and (d)
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request such person or persons to execute the “Acknowledgment and Agreement to
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Be Bound” that is attached hereto as Exhibit A.
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9.
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Without written permission from the Designating Party or a court order secured
FILING PROTECTED MATERIAL
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after appropriate notice to all interested persons, a party may not file in the public
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record in this action any Protected Material. Instead, the Receiving Party shall file a
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redacted version of the document containing Protected Material and mandatory
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chambers copies of unredacted documents shall be submitted in an appropriate
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envelope as set forth in Local Rule 79-5 of the Central District of California. The
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burden is then on the Designating Party to comply with Local Rule 79-5 by filing an
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application supported by competent evidence and proposed order to seal with the
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Court. If the Designating Party does not make such an application to seal within five
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(5) court days of the redacted materials being filed, then the Receiving Party shall
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file an unredacted version.
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10.
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This Protective Order shall survive the final termination of this action, to the
DURATION AND FINAL DISPOSITION
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extent that the information contained in “Confidential” or “Attorney’s Eyes Only”
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material is not or does not become known to the public, and the Court shall retain
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jurisdiction to resolve any dispute concerning the use of information disclosed
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hereunder. Within 60 days of termination of this case, counsel for the Parties shall
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assemble and return to each other all documents, materials, and deposition transcripts
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designated as “Confidential” or “Attorney’s Eyes Only” material, and all copies of
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the same, or shall certify the destruction thereof. Any action by this Court with
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respect to disposition of “Confidential” material shall be preceded by an ex parte
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motion for an order authorizing the return of all “Confidential” and “Attorney’s Eyes
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Only” material to the Party that produced the information or the destruction thereof.
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Notwithstanding this provision, counsel are entitled to retain an archival copy
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of all pleadings, motion papers, transcripts, legal memoranda, correspondence, or
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attorney work product, even if such materials contain Protected Material. Any such
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archival copies that contain or constitute Protected Material remain subject to this
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Protective Order.
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11.
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INADVERTENT DISCLOSURE OF PRIVILEGED
INFORMATION
Under Rule 502 of the Federal Rules of Evidence and Rule 26(b)(5)(B) of the
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Federal Rules of Civil Procedure, incorporated herein by reference, the inadvertent or
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unintentional disclosure by the Producing Party or non-party of information subject to
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the attorney-client privilege or work-product doctrine, or any other applicable
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privilege or immunity, shall not be deemed a waiver in whole or in part of the Party’s
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or nonparty’s claim of privilege or work-product immunity, either as to the specific
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information disclosed or as to any other information relating thereto or on the same or
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related subject matter. If a party or non-party has inadvertently produced information
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subject to a claim of immunity or privilege, the Party or non-party shall have the right
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to claw back inadvertently produced privileged or work-product documents. The
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Receiving Party, upon request, shall return or destroy the inadvertently produced
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materials within five (5) court days of the request, and all copies of those materials
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that may have been made and any notes regarding those materials shall be destroyed.
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The Party returning such information may move the Court for an order compelling
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production of such information including on the grounds that such production was not
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inadvertent or unintentional. However, the inadvertent production of privileged or
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otherwise protected materials cannot be a basis for seeking production.
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12.
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12.1 Right to Further Relief. Nothing in this Protective Order abridges the
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MISCELLANEOUS
right of any person to seek its modification by the Court in the future.
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12.2 Right to Assert Other Objections. By having stipulated to the entry of
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this Protective Order, no Party waives any right it otherwise would have to object to
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disclosing or producing any information or item on any ground not addressed in this
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Protective Order. Similarly, no Party waives any right to object on any ground to use
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in evidence of any of the material covered by this Protective Order.
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12.3 Injunctive Relief. The Parties shall not use or reveal, directly or
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indirectly, Protected Material in violation of this Protective Order. The Parties
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stipulate that injunctive relief is an appropriate remedy to prevent any person from
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using or disclosing Protected Material in violation of this Protective Order. In the
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event this Protective Order is violated or a violation is threatened, the Producing or
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Designating Party may apply to the Court to obtain injunctive relief. In the event
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such a motion or application is brought, the Receiving Party or other person subject
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to this Protective Order shall not employ, as a defense thereto, the claim that the
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movant possesses an adequate remedy at law. The Parties waive and release any and
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all requirements for a bond or undertaking to support any injunctive relief for the
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enforcement of this Protective Order.
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12.4 Notice: Transmission by electronic mail is acceptable for all notification
purposes herein.
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12.5 Advice to Client: Nothing in this Protective Order shall bar or otherwise
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restrict counsel from rendering advice to his or her client with respect to this litigation
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and, in the course thereof, relying upon his or her examination of CONFIDENTIAL
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or HIGHLY CONFIDENTIAL – ATTORNEY’S EYES ONLY materials produced
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or exchanged in this litigation.
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IT IS SO ORDERED.
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Dated: December 31, 2012
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_____________________________________
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MARGARET A. NAGLE
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UNITED STATES MAGISTRATE JUDGE
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EXHIBIT A
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UNITED STATES DISTRICT COURT
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CENTRAL DISTRICT OF CALIFORNIA – WESTERN DIVISION
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Case No. CV 12-1684 PSG (MANx)
LOREN STONE, individually and on
behalf of all others similarly situated,
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Plaintiff,
AGREEMENT TO BE BOUND BY
PROTECTIVE ORDER
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v.
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HOWARD JOHNSON
INTERNATIONAL, INC., a Delaware
Corporation; and DOES 1 – 10,
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Defendants.
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I, __________________________________, in connection with the above-
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captioned lawsuit, hereby acknowledge that I am to be provided access to
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confidential information supplied by other parties and/or non-parties, as defined in
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the Protective Order dated December 31, 2012.
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My address is ___________________________________________________.
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My present employer or the Party I have been retained by is
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_____________________________.
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My present occupation or job description and job title is
________________________________.
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I certify my understanding that the confidential information is being provided
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to me pursuant to the terms and restrictions of the aforesaid Protective Order and that
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I have been given a copy of and have read and understood my obligations under that
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Protective Order. I hereby agree to be bound by the terms of the Protective Order. I
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understand that the confidential information and my copies or notes relating thereto
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may be disclosed to or discussed with only those persons permitted by the Protective
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Order to receive such information.
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I will return on request all materials containing confidential information, copies
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thereof, and notes that I have prepared relating thereto, to outside counsel of record
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for the party with whom I am associated.
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I hereby submit to the jurisdiction of this Court for the purpose of enforcement
of the Protective Order and waive any and all objections to jurisdiction and venue.
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Respectfully submitted,
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Dated:
By:
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