Star Fabrics, Inc. v. Ideeli, Inc. et al
Filing
48
PROTECTIVE ORDER by Magistrate Judge Alka Sagar. re Stipulation for Protective Order 47 . (afe)
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Stephen M. Doniger (SBN 179314)
stephen@donigerlawfirm.com
Scott A. Burroughs (SBN 235718)
scott@donigerlawfirm.com
Howard S. Han (SBN 243406)
hhan@donigerlawfirm.com
DONIGER/BURROUGHS APC
603 Rose Avenue
Venice, California 90291
Telephone: (310) 590-1820
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Attorneys for Plaintiff
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UNITED STATES DISTRICT COURT
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CENTRAL DISTRICT OF CALIFORNIA
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STAR FABRICS, INC., a California
Corporation,
Plaintiff,
STIPULATED PROTECTIVE
ORDER
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Case No.: CV14-02968- MWF-ASx
Magistrate Judge Alka Sagar Presiding
[DISCOVERY MATTER]
v.
IDEELI, INC., a Delaware Corporation;
et. al.;
Defendants.
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-1STIPULATED PROTECTIVE ORDER
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1.
A. PURPOSES AND LIMITATIONS
Discovery in this action is likely to involve production of confidential,
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proprietary, or private information for which special protection from public disclosure
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and from use for any purpose other than prosecuting this litigation may be warranted.
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Accordingly, the parties hereby stipulate to and petition the Court to enter the
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following Stipulated Protective Order. The parties acknowledge that this Order does
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not confer blanket protections on all disclosures or responses to discovery and that the
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protection it affords from public disclosure and use extends only to the limited
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information or items that are entitled to confidential treatment under the applicable
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legal principles. The parties further acknowledge, as set forth in Section 12.3, below,
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that this Stipulated Protective Order does not entitle them to file confidential
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information under seal; Civil Local Rule 79-5 sets forth the procedures that must be
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followed and the standards that will be applied when a party seeks permission from
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the court to file material under seal.
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B. GOOD CAUSE STATEMENT
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This action is likely to involve trade secrets, customer and pricing lists and
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other valuable commercial, financial, and/or proprietary information for which special
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protection from public disclosure and from use for any purpose other than prosecution
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of this action is warranted. Such confidential and proprietary materials and
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information consist of, among other things, confidential business or financial
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information, information regarding confidential business practices or other
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commercial information (including information implicating privacy rights of third
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parties), information otherwise generally unavailable to the public, or which may be
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privileged or otherwise protected from disclosure under state or federal statutes, court
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rules, case decisions, or common law. Accordingly, to expedite the flow of
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information, to facilitate the prompt resolution of disputes over confidentiality of
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discovery materials, to adequately protect information the parties are entitled to keep
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confidential, to ensure that the parties are permitted reasonable necessary uses of such
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material in preparation for and in the conduct of trial, to address their handling at the
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end of the litigation, and serve the ends of justice, a protective order for such
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information is justified in this matter. It is the intent of the parties that information
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will not be designated as confidential or highly confidential for tactical reasons and
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that nothing be so designated without a good faith belief that it has been maintained in
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a confidential, non-public manner, and there is good cause why it should not be part of
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the public record of this case.
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2.
DEFINITIONS
2.1
Action: the federal law suit titled Star Fabrics, Inc. v. Ideeli, Inc., et al.,
CV14-02968-MWF-AS.
2.2
Challenging Party: a Party or Non-Party that challenges the designation
of information or items under this Order.
2.3
“CONFIDENTIAL” Information or Items: information (regardless of
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how it is generated, stored or maintained) or tangible things that qualify for protection
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under Federal Rule of Civil Procedure 26(c), and as specified above in the Good
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Cause Statement.
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2.4
Counsel: Outside Counsel of Record and House Counsel (as well as their
support staff).
2.5
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
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“CONFIDENTIAL.”
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2.6
Disclosure or Discovery Material: all items or information, regardless of
the medium or manner in which it is generated, stored, or maintained (including,
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among other things, testimony, transcripts, and tangible things), that are produced or
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generated in disclosures or responses to discovery in this matter.
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2.7
Expert: a person with specialized knowledge or experience in a matter
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pertinent to the litigation who has been retained by a Party or its counsel to serve as an
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expert witness or as a consultant in this Action.
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2.8
House Counsel: attorneys who are employees of a party to this Action.
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House Counsel does not include Outside Counsel of Record or any other outside
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counsel.
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2.9
Non-Party: any natural person, partnership, corporation, association, or
other legal entity not named as a Party to this action.
2.10 Outside Counsel of Record: attorneys who are not employees of a party
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to this Action but are retained to represent or advise a party to this Action and have
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appeared in this Action on behalf of that party or are affiliated with a law firm which
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has appeared on behalf of that party, and includes support staff.
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2.11 Party: any party to this Action, including all of its officers, directors,
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employees, consultants, retained experts, and Outside Counsel of Record (and their
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support staffs).
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2.12 Producing Party: a Party or Non-Party that produces Disclosure or
Discovery Material in this Action.
2.13 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, and organizing, storing, or retrieving data in any form or medium)
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and their employees and subcontractors.
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2.14 Protected Material: any Disclosure or Discovery Material that is
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designated as “CONFIDENTIAL,” “HIGHLY CONFIDENTIAL,” or “HIGHLY
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CONFIDENTIAL – ATTORNEY’S EYES ONLY.”
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-4STIPULATED PROTECTIVE ORDER
2.15 Receiving Party: a Party that receives Disclosure or Discovery Material
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from a Producing Party.
2.16 HIGHLY CONFIDENTIAL or HIGHLY CONFIDENTIAL
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ATTORNEY’S EYES ONLY information or items: any information (regardless of
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how it is generated, stored or maintained) or tangible things that qualify for protection
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under Federal Rule of Civil Procedure 26(c), and as specified above in the Good
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Cause Statement for which disclosure to another party would result in harm to the
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Designating Party.
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3.
SCOPE
The protections conferred by this Stipulation and Order cover not only
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Protected Material (as defined above), but also (1) any information copied or extracted
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from Protected Material; (2) all copies, excerpts, summaries, or compilations of
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Protected Material; and (3) any testimony, conversations, or presentations by Parties
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or their Counsel that might reveal Protected Material.
Any use of Protected Material at trial shall be governed by the orders of the trial
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judge. This Order does not govern the use of Protected Material at trial.
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4.
DURATION
Even after final disposition of this litigation, the confidentiality obligations
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imposed by this Order shall remain in effect until a Designating Party agrees
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otherwise in writing or a court order otherwise directs. Final disposition shall be
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deemed to be the later of (1) dismissal of all claims and defenses in this Action, with
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or without prejudice; and (2) final judgment herein after the completion and
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exhaustion of all appeals, rehearings, remands, trials, or reviews of this Action,
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including the time limits for filing any motions or applications for extension of time
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pursuant to applicable law.
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5.
DESIGNATING PROTECTED MATERIAL
5.1
Exercise of Restraint and Care in Designating Material for Protection.
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Each Party or Non-Party that designates information or items for protection under this
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Order must take care to limit any such designation to specific material that qualifies
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under the appropriate standards. The Designating Party must designate for protection
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only those parts of material, documents, items, or oral or written communications that
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qualify so that other portions of the material, documents, items, or communications
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for which protection is not warranted are not swept unjustifiably within the ambit of
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this Order.
Mass, indiscriminate, or routinized designations are prohibited. Designations
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that are shown to be clearly unjustified or that have been made for an improper
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purpose (e.g., to unnecessarily encumber the case development process or to impose
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unnecessary expenses and burdens on other parties) may expose the Designating Party
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to sanctions.
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If it comes to a Designating Party’s attention that information or items that it
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designated for protection do not qualify for protection, that Designating Party must
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promptly notify all other Parties that it is withdrawing the inapplicable designation.
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5.2
Manner and Timing of Designations. Except as otherwise provided in
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this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
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stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
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under this Order must be clearly so designated before the material is disclosed or
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produced.
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Designation in conformity with this Order requires:
(a) for information in documentary form (e.g., paper or electronic
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documents, but excluding transcripts of depositions or other pretrial or trial
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proceedings), that the Producing Party affix at a minimum, the legend
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“CONFIDENTIAL,” “HIGHLY CONFIDENTIAL,” or “HIGHLY
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CONFIDENTIAL ATTORNEY’S EYES ONLY” (hereinafter
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“CONFIDENTIAL legend”), to each page that contains protected material. If
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only a portion or portions of the material on a page qualifies for protection, the
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Producing Party also must clearly identify the protected portion(s) (e.g., by
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making appropriate markings in the margins).
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A Party or Non-Party that makes original documents available for
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inspection need not designate them for protection until after the inspecting Party
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has indicated which documents it would like copied and produced. During the
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inspection and before the designation, all of the material made available for
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inspection shall be deemed “HIGHLY CONFIDENTIAL.” After the inspecting
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Party has identified the documents it wants copied and produced, the Producing
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Party must determine which documents, or portions thereof, qualify for
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protection under this Order. Then, before producing the specified documents,
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the Producing Party must affix the “CONFIDENTIAL legend” to each page that
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contains Protected Material. If only a portion or portions of the material on a
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page qualifies for protection, the Producing Party also must clearly identify the
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protected portion(s) (e.g., by making appropriate markings in the margins).
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(b) for testimony given in depositions that the Designating Party identify
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the Disclosure or Discovery Material on the record, before the close of the
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deposition all protected testimony.
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(c) for information produced in some form other than documentary and
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for any other tangible items, that the Producing Party affix in a prominent place
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on the exterior of the container or containers in which the information is stored
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the legend “CONFIDENTIAL,” “HIGHLY CONFIDENTIAL,” or “HIGHLY
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CONFIDENTIAL – ATTORNEY’S EYES ONLY.” If only a portion or
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portions of the information warrants protection, the Producing Party, to the
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extent practicable, shall identify the protected portion(s).
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5.3
Inadvertent Failures to Designate. If timely corrected, an inadvertent
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failure to designate qualified information or items does not, standing alone, waive the
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Designating Party’s right to secure protection under this Order for such material.
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Upon timely correction of a designation, the Receiving Party must make reasonable
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efforts to assure that the material is treated in accordance with the provisions of this
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Order.
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6.
CHALLENGING CONFIDENTIALITY DESIGNATIONS
6.1
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Timing of Challenges. Any Party or Non-Party may challenge a
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designation of confidentiality at any time that is consistent with the Court’s
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Scheduling Order.
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Meet and Confer. The Challenging Party shall initiate the dispute
resolution process under Local Rule 37.1 et seq.
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The burden of persuasion in any such challenge proceeding shall be on
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the Designating Party. Frivolous challenges, and those made for an improper purpose
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(e.g., to harass or impose unnecessary expenses and burdens on other parties) may
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expose the Challenging Party to sanctions. Unless the Designating Party has waived or
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withdrawn the confidentiality designation, all parties shall continue to afford the
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material in question the level of protection to which it is entitled under the Producing
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Party’s designation until the Court rules on the challenge.
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7.
ACCESS TO AND USE OF PROTECTED MATERIAL
7.1
Basic Principles. A Receiving Party may use Protected Material that is
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disclosed or produced by another Party or by a Non-Party in connection with this
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Action only for prosecuting, defending, or attempting to settle this Action. Such
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Protected Material may be disclosed only to the categories of persons and under the
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conditions described in this Order. When the Action has been terminated, a Receiving
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Party must comply with the provisions of section 13 below (FINAL DISPOSITION).
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Protected Material must be stored and maintained by a Receiving Party at a
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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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7.2
Disclosure of “CONFIDENTIAL” Information or Items. Unless
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otherwise ordered by the court or permitted in writing by the Designating Party, a
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Receiving Party may disclose any information or item designated “CONFIDENTIAL”
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only to:
(a) the Receiving Party’s Outside Counsel of Record in this Action, as
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well as employees of said Outside Counsel of Record to whom it is reasonably
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necessary to disclose the information for this Action;
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(b) the officers, directors, and employees (including House Counsel) of
the Receiving Party to whom disclosure is reasonably necessary for this Action;
(c) Experts (as defined in this Order) of the Receiving Party to whom
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disclosure is reasonably necessary for this Action and who have signed the
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“Acknowledgment and Agreement to Be Bound” (Exhibit A);
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(d) the court and its personnel;
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(e) court reporters and their staff;
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(f) professional jury or trial consultants, mock jurors, and Professional
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Vendors to whom disclosure is reasonably necessary for this Action and who
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have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
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(g) the author or recipient of a document containing the information or a
custodian or other person who otherwise possessed or knew the information;
(h) during their depositions, witnesses ,and attorneys for witnesses, in the
Action to whom disclosure is reasonably necessary provided: (1) the deposing
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party requests that the witness sign the form attached as Exhibit 1 hereto; and
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(2) they will not be permitted to keep any confidential information unless they
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sign the “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless
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otherwise agreed by the Designating Party or ordered by the court. Pages of
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transcribed deposition testimony or exhibits to depositions that reveal Protected
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Material may be separately bound by the court reporter and may not be
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disclosed to anyone except as permitted under this Stipulated Protective Order;
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and
(i) any mediator or settlement officer, and their supporting personnel,
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mutually agreed upon by any of the parties engaged in settlement discussions.
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7.3
Disclosure of “HIGHLY CONFIDENTIAL” or “HIGHLY
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CONFIDENTIAL – ATTORNEY’S EYES ONLY” Information or Items. Unless
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otherwise ordered by the court or permitted in writing by the Designating Party, a
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Receiving Party may disclose any information or item designated “HIGHLY
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CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEY’S EYES ONLY”
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only to:
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(a) the Receiving Party’s Outside Counsel of Record in this Action, as
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well as employees of said Outside Counsel of Record to whom it is reasonably
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necessary to disclose the information for this Action;
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(b) Experts (as defined in this Order) of the Receiving Party to whom
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disclosure is reasonably necessary for this Action and who have signed the
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“Acknowledgment and Agreement to Be Bound” (Exhibit A);
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(c) the court and its personnel;
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(d) court reporters and their staff;
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(e) professional jury or trial consultants, mock jurors, and Professional
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Vendors to whom disclosure is reasonably necessary for this Action and who
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have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
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(f) the author or recipient of a document containing the information or a
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custodian or other person who otherwise possessed or knew the information;
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and
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(g) any mediator or settlement officer, and their supporting personnel,
mutually agreed upon by any of the parties engaged in settlement discussions.
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8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED
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IN OTHER LITIGATION
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If a Party is served with a subpoena or a court order issued in other litigation
that compels disclosure of any information or items designated in this Action as
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“CONFIDENTIAL,” “HIGHLY CONFIDENTIAL,” or “HIGHLY CONFIDENTIAL
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– ATTORNEY’S EYES ONLY,” that Party must:
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(a) promptly notify in writing the Designating Party. Such notification
shall include a copy of the subpoena or court order;
(b) promptly notify in writing the party who caused the subpoena or order
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to issue in the other litigation that some or all of the material covered by the
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subpoena or order is subject to this Protective Order. Such notification shall
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include a copy of this Stipulated Protective Order; and
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(c) cooperate with respect to all reasonable procedures sought to be
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pursued by the Designating Party whose Protected Material may be affected. If
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the Designating Party timely seeks a protective order, the Party served with the
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subpoena or court order shall not produce any information designated in this
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action as “CONFIDENTIAL,” “HIGHLY CONFIDENTIAL,” or “HIGHLY
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CONFIDENTIAL – ATTORNEY’S EYES ONLY,” before a determination by
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the court from which the subpoena or order issued, unless the Party has
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obtained the Designating Party’s permission. The Designating Party shall bear
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the burden and expense of seeking protection in that court of its confidential
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material and nothing in these provisions should be construed as authorizing or
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encouraging a Receiving Party in this Action to disobey a lawful directive from
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another court.
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9.
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PRODUCED IN THIS LITIGATION
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A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
(a) The terms of this Order are applicable to information produced by a
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Non-Party in this Action and designated as “CONFIDENTIAL,” “HIGHLY
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CONFIDENTIAL,” or “HIGHLY CONFIDENTIAL – ATTORNEY’S EYES
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ONLY.” Such information produced by Non-Parties in connection with this
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litigation is protected by the remedies and relief provided by this Order.
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Nothing in these provisions should be construed as prohibiting a Non-Party
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from seeking additional protections.
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(b) In the event that a Party is required, by a valid discovery request, to
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produce a Non-Party’s confidential information in its possession, and the Party
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is subject to an agreement with the Non-Party not to produce the Non-Party’s
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confidential information, then the Party shall:
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(1) promptly notify in writing the Requesting Party and the Non-
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Party that some or all of the information requested is subject to a
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confidentiality agreement with a Non-Party;
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(2) promptly provide the Non-Party with a copy of the Stipulated
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Protective Order in this Action, the relevant discovery request(s), and a
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reasonably specific description of the information requested; and
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(3) make the information requested available for inspection by the
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Non-Party, if requested.
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(c) If the Non-Party fails to seek a protective order from this court within
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14 days of receiving the notice and accompanying information, the Receiving
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Party may produce the Non-Party’s confidential information responsive to the
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discovery request. If the Non-Party timely seeks a protective order, the
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Receiving Party shall not produce any information in its possession or control
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that is subject to the confidentiality agreement with the Non-Party before a
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determination by the court. Absent a court order to the contrary, the Non-Party
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shall bear the burden and expense of seeking protection in this court of its
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Protected Material.
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10.
UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed
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Protected Material to any person or in any circumstance not authorized under this
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Stipulated Protective Order, the Receiving Party must immediately (a) notify in
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writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
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to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
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persons to whom unauthorized disclosures were made of all the terms of this Order,
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and (d) request such person or persons to execute the “Acknowledgment and
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Agreement to Be Bound” that is attached hereto as Exhibit A.
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11.
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PROTECTED MATERIAL
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INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE
When a Producing Party gives notice to Receiving Parties that certain
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inadvertently produced material is subject to a claim of privilege or other protection,
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the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
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Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
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may be established in an e-discovery order that provides for production without prior
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privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the
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parties reach an agreement on the effect of disclosure of a communication or
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information covered by the attorney-client privilege or work product protection, the
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parties may incorporate their agreement in the stipulated protective order submitted to
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the court.
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12.
12.1 Right to Further Relief. Nothing in this Order abridges the right of any
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MISCELLANEOUS
person to seek its modification by the Court in the future.
12.2 Right to Assert Other Objections. By stipulating to the entry of this
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Protective Order no Party waives any right it otherwise would have to object
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disclosing or producing any information or item on any ground not addressed in this
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Stipulated Protective Order. Similarly, no Party waives any right to object on any
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ground to use in evidence of any of the material covered by this Protective Order.
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12.3 Filing Protected Material. A Party that seeks to file under seal any
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Protected Material must comply with Civil Local Rule 79-5. Protected Material may
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only be filed under seal pursuant to a court order authorizing the sealing of the
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specific Protected Material at issue. If a Party's request to file Protected Material
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under seal is denied by the court, then the Receiving Party may file the information in
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the public record unless otherwise instructed by the court.
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13.
FINAL DISPOSITION
After the final disposition of this Action, as defined in paragraph 4, within 60
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days of a written request by the Designating Party, each Receiving Party must return
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all Protected Material to the Producing Party or destroy such material. As used in this
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subdivision, “all Protected Material” includes all copies, abstracts, compilations,
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summaries, and any other format reproducing or capturing any of the Protected
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Material. Whether the Protected Material is returned or destroyed, the Receiving Party
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must submit a written certification to the Producing Party (and, if not the same person
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or entity, to the Designating Party) by the 60 day deadline that (1) identifies (by
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category, where appropriate) all the Protected Material that was returned or destroyed
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and (2) affirms that the Receiving Party has not retained any copies, abstracts,
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compilations, summaries or any other format reproducing or capturing any of the
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Protected Material. Notwithstanding this provision, Counsel are entitled to retain an
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archival copy of all pleadings, motion papers, trial, deposition, and hearing transcripts,
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legal memoranda, correspondence, deposition and trial exhibits, expert reports,
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attorney work product, and consultant and expert work product, even if such materials
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contain Protected Material. Any such archival copies that contain or constitute
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Protected Material remain subject to this Protective Order as set forth in Section 4
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(DURATION).
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14.
Any violation of this Order may be punished by any and all appropriate
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measures including, without limitation, contempt proceedings and/or monetary
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sanctions.
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IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
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Dated: February 6, 2015
By:
/s/ Howard S. Han
Howard S. Han, Esq.
DONIGER / BURROUGHS
Attorneys for Plaintiff Star Fabrics, Inc.
Dated: February 6, 2015
By:
/s/ H. Kim Sim
H. Kim Sim, Esq.
CONKLE, KREMER & ENGEL
Attorneys for Defendant Gracia Fashion
Corp.
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Dated: February 6, 2015
By:
/s/ Sam G. Brooks
Sam G. Brooks, Esq.
CALL & JENSEN
Attorneys for Defendants Groupon, Inc.
and Ideeli, Inc.
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FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
/s/
DATED: February 9, 2015
________________________________
Honorable Alka Sagar
United States Magistrate Judge
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EXHIBIT A
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ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
I, _____________________________ [print or type full name], of
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_______________________________________ [print or type full address], declare
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under penalty of perjury that I have read in its entirety and understand the Stipulated
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Protective Order that was issued by the United States District Court for the Central
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District of California on __________ in the case of Star Fabrics, Inc. v. Ideeli, Inc., et
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al., CV14-02968-MWF-AS. I agree to comply with and to be bound by all the terms
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of this Stipulated Protective Order and I understand and acknowledge that failure to so
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comply could expose me to sanctions and punishment in the nature of contempt. I
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solemnly promise that I will not disclose in any manner any information or item that is
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subject to this Stipulated Protective Order to any person or entity except in strict
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compliance with the provisions of this Order.
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I further agree to submit to the jurisdiction of the United States District Court
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for the Central District of California for the purpose of enforcing the terms of this
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Stipulated Protective Order, even if such enforcement proceedings occur after
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termination of this action. I hereby appoint __________________________ [print or
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type full name] of _______________________________________ [print or type full
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address and telephone number] as my California agent for service of process in
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connection with this action or any proceedings related to enforcement of this
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Stipulated Protective Order.
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Date: ______________________________________
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City and State where sworn and signed: _________________________________
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Printed name: _______________________________
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Signature: __________________________________
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- 17 STIPULATED PROTECTIVE ORDER
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