Glen Sassoon v. Lowe's HIW Inc et al

Filing 15

Stipulated PROTECTIVE ORDER by Magistrate Judge Charles F. Eick. (sp)

2:13-cv-03233-RGK-E Document 14

CHARLES D. MAY, ESQ.; STATE BAR NO.: 129663
GENE B. SHARAGA ESQ. STATE BAR NO.: 131661
2
THARPE & HOWELL, lIP
15250 Ventura Blvd, Ninth Floor
3 Sherman Oaks, California 91403
[phone]; [phone] fax
4 E-Mail: cmay(tharpe-howell.com
E-Mail: gsharaa(atharpe-howelLcom
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Attorneys for Defendants,
LOWE’S HIW,

FILED
CLERU.DISLRKT COURT

JAN 92014

/2
NTRM DiSimcTjJFoRN I
BY
DEPUT

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UNITED STATES DISTRICT COURT

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CENTRAL DISTRICT OF CALIFORNIA - WESTERN DIVISION

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111

o.o

GLEN SASSOON,
Plaintiff,

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(Los Angeles County Superior Court Case
No.: PC54009)
5-,J’)fr)yd

V.

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LOWE’S HIW, INC. and DOES 1 to
100, Inclusive,

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Discovery Matter

Defendants.

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C#)

CASE NO.: 2:13-CV-03233-RGK(Ex)

It appearing to the Court that the Plaintiff and Defendant are in agreement that

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Lowe’s HIW, Inc. (hereinafter "the Defendant") possesses proprietary policies and

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procedures, as well as personnel files of present and former employees, that include

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confidential information that may be subject to discovery in the proceedings in this

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matter but which should not be made available to the public generally, this Court

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hereby orders that:

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1.

All documents produced or information disclosed and any other

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documents or records designated as "confidential" by the Defendant shall be

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revealed only to Plaintiff, counsel of record in this case, paralegals and secretarial

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employees under counsel’s direct supervision, and such persons as are employed by

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counsel to act as experts in this action. The information considered as "confidential"

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and disclosed only in accord with the terms of this paragraph shall include, without

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limitation, all of the Defendant’s policies and procedures, as well as personnel
AGREED ORDER OF PROTECTION

Casl4 2:13-cv-03233-RGK-E Document 14

1 records, including disciplinary records, identity, or any other information or
2 documentation supplied by the Defendant in response to Plaintiffs Interrogatories or
3 Requests for Production.
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2.
Counsel for Plaintiff shall use all documents and information produced
5 or disclosed by the Defendant solely for the purposes of preparation for and trial of
6 this action. This protective order in no way precludes the plaintiff from introducing
7 documents as exhibits at trial that would otherwise be admissible. Other than for use
8 at trial, under no other circumstances shall information or materials covered by this
9 Protective Order be disclosed to anyone other than Plaintiffs counsel of record in
10 this action, paralegals, secretarial employees under counsel’s direct supervision, and
11 such persons employed to act as experts in this action. At the conclusion of the
12 proceedings in this action, all documents and information subject to this Order,

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including any copies or extracts or summaries thereof, or documents containing

14 information taken therefrom, shall be returned to counsel for the Defendant.
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Prior to disclosure of any documents designated as "confidential" to
3.
16 paralegals or secretarial employees of counsel or Plaintiff, counsel for Plaintiff shall
17 require such employees to read this Protective Order and agree to be bound by its
18 terms.
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4.

If counsel for Plaintiff determines that for purposes of this action,

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documents or information produced by the Defendant and designated as

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"confidential" must be revealed to a person employed to act as an expert in this

22 action, then counsel may reveal the designated documents or information to such
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person, after first complying with the following:
(a) Counsel for the Plaintiff shall have the expert read this Order and shall
explain the contents thereof to such expert.
(b) Counsel for the Plaintiff shall require such expert to sign a copy of this

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protective order that states: "I have read and understood the terms of

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this protective order. I further agree to be bound by its terms." Nothing
-2AGREED ORDER OF PROTECTION
Sassoon v. Lowe’s 111W, Inc.
(.0.

Case 2:13-cv-03233-RGK-E Document 14

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in this paragraph shall be deemed to enlarge the right of Defendant to

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conduct discovety of any of Plaintiffs experts, except solely with

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respect to the ability of such, expert to protect confidential information

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and documents from. re-disclosure.

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5.

In accordance with Local Rule 79-5. 1, any , papers filed with the Court

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that contain information, that has been designated as "Confidential" or "Attorneys

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Eyes Only," shall be accompanied by an application to file the tapers or the portion

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thereof containing the designated information under seal; and the application, shall be

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directed to the judge to whom. the papers are directed. For motions, the parties shall

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fi.ie.a redacted version o .f the notion and supporting papers
6.

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IIi! ::
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At the conclusion of the proceedings in this action, all documents and

iiifrniation subject to this Order, including any copies or extracts or summaries
thereof, or documents containing information taken therefrom, shall be returned to
counsel for the Defendant.
7.

This Order is subject. to revocation ’atd modification by Order of the

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Court upon written stipulation of the parties, or upon motion and reasonable notice,

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including opportunity Loi hcai ing and presentation of evidence.

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217
4’

Entered this Ad ay

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APPROVED FOR ENTRY:

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Attorney for Plaintiff, Glen Sas

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Attorney for Defenda t Lowe’s

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AGREED RIDER OF PROT1C110
S(fl)it Y

Lo,ts I I1\Y. Inc.