Brand Tarzana Surgical Institute Inc v. United Health Group Inc. et al
Filing
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PROTECTIVE ORDER by Magistrate Judge Andrew J. Wistrich GRANTED. 19 (see document for further details) (yb)
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UNITED STATES DISTRICT COURT
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CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION
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[PROPOSED] STIPULATED
PROTECTIVE ORDER
Plaintiff,
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Case No. 2:15-cv-09911 CBM (AJWx)
BRAND TARZANA SURGICAL
INSTITUTE, INC., a California
Corporation,
Judge: Hon. Consuelo B. Marshall
v.
Magistrate Judge: Hon. Andrew J.
Wistrich
UNITED HEALTH GROUP, INC.;
UNITED HEALTHCARE SERVICES,
INC.; UNITED HEALTHCARE
INSURANCE COMPANY, and DOES
1-100,
Trial Date: None Set
Defendants.
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1.
PURPOSES AND LIMITATIONS
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Disclosure and discovery activity in this action are likely to involve
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production of confidential, proprietary, or private information for which special
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protection from public disclosure and from use for any purpose other than
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prosecuting this litigation may be warranted. Accordingly, the parties hereby
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stipulate to and petition the court to enter the following Stipulated Protective
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Order. The parties acknowledge that this Order does not confer blanket protections
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on all disclosures or responses to discovery and that the protection it affords from
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public disclosure and use extends only to the limited information or items that are
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entitled to confidential treatment under the applicable legal principles. The parties
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[PROPOSED] STIPULATED PROTECTIVE ORDER
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further acknowledge, as set forth in Section 12.3, below, that this Proposed
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Protective Order does not entitle them to file confidential information under seal;
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Local Rule 79-5 sets forth the procedures that must be followed and the standards
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that will be applied when a party seeks permission from the court to file material
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under seal.
Based upon the Stipulation of the parties and pursuant to Rule 26(c) of the
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Federal Rules of Civil Procedure, IT IS HEREBY ORDERED that:
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2.
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DEFINITIONS
2.1
Challenging Party: a Party or Non-Party that challenges the
designation of information or items under this Order.
2.2
“CONFIDENTIAL” Information or Items: information (regardless of
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how it is generated, stored or maintained) or tangible things that qualify for
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protection under Federal Rule of Civil Procedure 26(c), including but not limited to
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patient records and data, claim files, non-public financial records and data,
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employee or personnel files, customer or client lists, confidential contracts, other
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healthcare-related information protected by The Health Insurance Portability and
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Accountability Act of 1996, and all other information that the party in good faith
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believes will, if disclosed, cause harm to the Producing Party’s competitive
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position.
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2.3
“CONFIDENTIAL – ATTORNEYS’ EYES ONLY” Information or
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Items: subset of information (regardless of how it is generated, stored or
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maintained) or tangible things that qualify for protection under Federal Rule of
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Civil Procedure 26(c) subject to limited disclosure as set forth in Paragraph 7.3,
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that will, if disclosed, cause substantial competitive and economic harm to the
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Producing Party. This includes, but is not limited to, trade secrets, United’s
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proprietary claims-review and audit processes, and all other non-public, proprietary
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financial, regulatory, or strategic information and data, to the extent that any of
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[PROPOSED] STIPULATED PROTECTIVE ORDER
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these categories of information or tangible things will, if disclosed, cause
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substantial competitive and economic harm to the Producing Party.
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2.4
Counsel (without qualifier): Outside Counsel of Record and House
Counsel (as well as their support staff).
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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” or “CONFIDENTIAL – ATTORNEYS’ EYES ONLY.”
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2.5
Disclosure or Discovery Material: all items or information, regardless
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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 provided,
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produced or generated in relation to the claims and disputes in this matter or in
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disclosures or responses to discovery in this matter.
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2.6
Expert: a person with specialized knowledge or experience in a
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matter pertinent to the litigation who has been retained by a Party or its counsel to
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serve as an expert witness or as a consultant in this action.
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2.7
House Counsel: attorneys who are employees of a party to this
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action. House Counsel does not include Outside Counsel of Record or any other
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outside counsel.
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2.8
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Non-Party: any natural person, partnership, corporation, association,
or other legal entity not named as a Party to this action.
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Outside Counsel of Record: attorneys who are not employees of a
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party to this action but are retained to represent or advise a party to this action and
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have appeared in this action on behalf of that party or are affiliated with a law firm
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which has appeared on behalf of that party.
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2.10 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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[PROPOSED] STIPULATED PROTECTIVE ORDER
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2.11 Producing Party: a Party or Non-Party that produces Disclosure or
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Discovery Material in this action.
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2.12 Professional Vendors: persons or entities that provide litigation
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support 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.
2.13
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Protected Material: any Disclosure or Discovery Material that is
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designated as “CONFIDENTIAL” or CONFIDENTIAL – ATTORNEYS’ EYES
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ONLY.”
2.14 Receiving Party: a Party that receives Disclosure or Discovery
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Material from a Producing Party.
2.15 United: Collectively, UnitedHealth Group, Inc., United Healthcare
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Services, Inc.; and United Healthcare Insurance Company, Inc.
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3.
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SCOPE
The protections conferred by this Stipulation and Order cover not only
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Protected Material (as defined above), but also any and all copies, excerpts, or
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compilations of Protected Material. However, the protections conferred by this
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Stipulation and Order do not cover the following information: (a) any information
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that is in the public domain at the time of disclosure to a Receiving Party or
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becomes part of the public domain after its disclosure to a Receiving Party as a
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result of publication not involving a violation of this Order, including becoming
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part of the public record through trial or otherwise; and (b) any information known
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to the Receiving Party prior to the disclosure or obtained by the Receiving Party
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after the disclosure from a source who obtained the information lawfully and under
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no obligation of confidentiality to the Designating Party. Any use of Protected
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Material at trial shall be governed by a separate agreement or order.
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[PROPOSED] STIPULATED PROTECTIVE ORDER
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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,
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with 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
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time pursuant to applicable law.
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5.
DESIGNATING PROTECTED MATERIAL
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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
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under this Order must take care to limit any such designation to specific material
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that qualifies under the appropriate standards.
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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 mistaken designation.
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5.2
Manner and Timing of Designations.
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Except as otherwise provided in this Order (see, e.g., second paragraph of
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Section 5.2(a) below), or as otherwise stipulated or ordered, Disclosure or
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Discovery Material that qualifies for protection under this Order must be clearly so
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designated before the material is disclosed or produced. Designation in conformity
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with this Order requires:
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(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 the legend “CONFIDENTIAL” or
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“CONFIDENTIAL – ATTORNEYS’ EYES ONLY” to each page that contains
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protected material. If only a portion or portions of the material on a page qualifies
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[PROPOSED] STIPULATED PROTECTIVE ORDER
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for protection, the Producing Party also must clearly identify the protected
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portion(s) (e.g., by making appropriate markings in the margins).
(b) for testimony given in a deposition, confidentiality designations
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shall be made either on the record or by written notice to the other party within 14
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days of receipt of the transcript. Unless otherwise agreed, depositions shall be
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treated as “Confidential” during the 14-day period following receipt of the
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transcript. The deposition of any witness (or any portion of such deposition) that
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encompasses Confidential information shall be taken only in the presence of
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persons who are qualified to have access to such information.
(c) for information produced in some form other than documentary
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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
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item is stored the legend “CONFIDENTIAL” or CONFIDENTIAL –
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ATTORNEYS’ EYES ONLY.” If only a portion or portions of the information or
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item warrant protection, the Producing Party, to the extent practicable, shall
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identify the protected portion(s).
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5.3
Inadvertent Failures to Designate.
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If timely corrected, an inadvertent failure to designate qualified information
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or items does not, standing alone, waive the Designating Party’s right to secure
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protection under this Order for such material. Upon timely correction of a
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designation, the Receiving Party must make reasonable efforts to assure that the
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material is treated in accordance with the provisions of this Order.
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6.
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CHALLENGING CONFIDENTIALITY DESIGNATIONS
All challenges to confidentiality designations shall proceed under Local Rule
37-1 through Local Rule 37-4.
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[PROPOSED] STIPULATED PROTECTIVE ORDER
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7.
ACCESS TO AND USE OF PROTECTED MATERIAL
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7.1
Basic Principles.
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A Receiving Party may use Protected Material that is disclosed or produced
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by another Party or by a Non-Party in connection with this case only for
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prosecuting, defending, or attempting to settle this litigation or related litigation
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involving some or all of the parties hereto. Such Protected Material may be
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disclosed only to the categories of persons and under the conditions described in
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this Order. When the litigation has been terminated, a Receiving Party must
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comply with the provisions of Section 13 below.
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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
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Unless otherwise ordered by the court or permitted in writing by the
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Designating Party, a Receiving Party may disclose any information or item
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designated “CONFIDENTIAL” only to:
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Disclosure of “CONFIDENTIAL” Information or Items.
(a) the Receiving Party’s Outside Counsel of Record in this action, as well
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as employees of said Outside Counsel of Record to whom it is reasonably
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necessary to disclose the information for this litigation;
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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 litigation;
(c) Experts (as defined in this Order) of the Receiving Party to whom
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disclosure is reasonably necessary for this litigation 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, professional jury or trial consultants, mock
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jurors, licensed private investigators retained by Counsel, and Professional
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Vendors to whom disclosure is reasonably necessary for this litigation and who
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have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
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(f) during their depositions, witnesses in the action to whom disclosure is
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reasonably necessary and who have signed the “Acknowledgment and Agreement
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to Be Bound” (Exhibit A), unless otherwise agreed by the Designating Party or
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ordered by the court. Pages of transcribed deposition testimony or exhibits to
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depositions that reveal Protected Material must be separately bound by the court
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reporter and may not be disclosed to anyone except as permitted under this
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Stipulated Protective Order.
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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.
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Disclosure of “CONFIDENTIAL – ATTORNEYS’ EYES ONLY”
Information or Items.
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Unless otherwise ordered by the court or permitted in writing by the
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Designating Party, a Receiving Party may disclose any information or item
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designated “CONFIDENTIAL – ATTORNEYS’ EYES ONLY” only to:
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(a) the Receiving Party’s Outside Counsel of Record in this action;
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(b) United’s House Counsel in this action;
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(c) Experts (as defined in this Order) of the Receiving Party to whom
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disclosure is reasonably necessary for this litigation 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, professional jury or trial consultants, mock
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jurors, licensed private investigators retained by Counsel, and Professional
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Vendors to whom disclosure is reasonably necessary for this litigation and who
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have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
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(f) during their depositions, witnesses in the action to whom disclosure is
reasonably necessary and who have signed the “Acknowledgment and Agreement
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to Be Bound” (Exhibit A), unless otherwise agreed by the Designating Party or
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ordered by the court. Pages of transcribed deposition testimony or exhibits to
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depositions that reveal Protected Material must be separately bound by the court
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reporter and may not be disclosed to anyone except as permitted under this
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Stipulated Protective Order.
(g) 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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8.
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PROTECTED MATERIAL SUBPOENAED OR ORDERED
PRODUCED
If a Party is served with a subpoena or a court order issued in other litigation
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that compels disclosure of any information designated by an opposing or third
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party in this Action as “CONFIDENTIAL” or “CONFIDENTIAL –
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ATTORNEYS’ EYES ONLY,” that Party must:
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(a) unless prohibited by a Court Order, or specifically prohibited by a statute
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or regulation cited to the producing party by the requesting party, promptly notify
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in writing the Designating Party. Such notification shall include a copy of the
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subpoena or court order, unless prohibited by law;
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(b) promptly notify in writing the party who caused the request, or subpoena,
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or order to issue in the other litigation that some or all of the material covered by
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the 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) when applicable, as set forth in ¶ (a), cooperate with respect to all
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reasonable procedures sought to be pursued by the Designating Party whose
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Protected Material may be affected. However, the parties must follow the
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procedures set forth in Federal Rule of Civil Procedure 45(d)(2) when asserting
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that subpoenaed or requested information is subject to a privilege. The filing of a
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motion for a protective order does not, by itself, stay compliance with a subpoena.
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If the Designating Party timely seeks a protective order from a court of
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competent jurisdiction, the Party served with the subpoena or court order shall not
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produce any information designated in this action as “CONFIDENTIAL” before a
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determination by the court from which the subpoena or order issued, unless the
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Party has obtained the Designating Party's permission or as otherwise required by
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law or court order. The Designating Party shall bear the burden and expense of
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seeking protection in that court of its confidential material and nothing in these
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provisions should be construed as authorizing or encouraging a Receiving Party in
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this Action to disobey a lawful directive from another court.
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9.
A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE
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PRODUCED
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9.1
The terms of this Order are applicable to information, documents
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and/or tangible things produced by a Non-Party in this action, and designated as
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“CONFIDENTIAL” or “CONFIDENTIAL – ATTORNEYS’ EYES ONLY.”
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Such information produced by Non-Parties, when so designated by the Non-Party
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upon production or by any other Party pursuant to Section 9.2 below, is protected
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by the remedies and relief provided by this Order. Nothing in these provisions
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should be construed as prohibiting a Non-Party from seeking additional
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protections.
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9.2
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 is
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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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(a) promptly notify in writing the Requesting Party and the Non-Party
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that some or all of the information requested is subject to a confidentiality
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agreement with a Non-Party;
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(b) promptly provide the Non-Party with a copy of the Stipulated
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Protective Order in this litigation, the relevant discovery request(s), and a
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reasonably specific description of the information requested; and
(c) make the information requested available for inspection by the
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Non-Party.
If the Non-Party fails to object or seek a protective order from this Court
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within fourteen (14) days of receiving the notice and accompanying information,
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the Receiving Party may produce the Non-Party’s confidential information
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responsive to the discovery request. If the Non-Party timely seeks a protective
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order, the Receiving Party shall not produce any information in its possession or
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control 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
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If a Receiving Party learns that, by inadvertence or otherwise, it has
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disclosed Protected Material to any person or in any circumstance not authorized
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under this Stipulated Protective Order, the Receiving Party must immediately (a)
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notify in writing the Designating Party of the unauthorized disclosures, (b) use its
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best efforts to retrieve all unauthorized copies of the Protected Material, (c) inform
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the person or persons to whom unauthorized disclosures were made of all the terms
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of this Order, and (d) request such person or persons to execute the
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“Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit
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A.
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11.
INADVERTENT PRODUCTION OF PRIVILEGED OR
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OTHERWISE PROTECTED MATERIAL
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In accordance with Federal Rule of Civil Procedure 26(b)(5)(B) and Federal
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Rule of Evidence 502, any Party who inadvertently produces Discovery Material
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[PROPOSED] STIPULATED PROTECTIVE ORDER
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that is privileged or otherwise immune from discovery shall, promptly upon
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discovery of such inadvertent production, so advise the Producing Party and
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request that the Discovery Materials be returned. The Receiving Party shall return,
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sequester, or destroy such inadvertently produced Discovery Materials, including
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all copies, within five (5) business days of receiving such a written request. The
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Party returning such inadvertently produced Discovery Materials may thereafter
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seek re-production of any such Discovery Materials pursuant to applicable law.
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12.
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MISCELLANEOUS
12.1 Right to Further Relief.
Nothing in this Order abridges the 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.
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By stipulating to the entry of this Protective Order no Party waives any right
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it otherwise would have to object to disclosing or producing any information or
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item on any ground not addressed in this Stipulated Protective Order. Similarly, no
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Party waives any right to object on any ground to use in evidence of any of the
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material covered by this Protective Order.
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12.3 Filing Protected Material.
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Without written permission from the Designating Party or a court order
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secured after appropriate notice to all interested persons, a Party may not file in the
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public record in this action any Protected Material. A Party that seeks to file under
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seal any Protected Material must comply with Local Rule 79-5. Protected Material
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may only be filed under seal pursuant to a court order authorizing the sealing of the
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specific Protected Material at issue. Pursuant to Local Rule 79-5, a sealing order
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will issue only upon a request establishing that the Protected Material at issue is
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privileged, protectable as a trade secret, or otherwise entitled to protection under
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the law. If a Receiving Party's request to file Protected Material under seal
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pursuant to Local Rule 79-5 is denied by the court, then the Receiving Party may
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file the information in the public record unless otherwise instructed by the court.
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13.
FINAL DISPOSITION
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Within 60 days after the final disposition of this action, as defined in
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paragraph 4, each Receiving Party must return all Protected Material to the
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Producing Party or destroy such material. As used in this subdivision, “all
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Protected Material” includes all copies, abstracts, compilations, summaries, and
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any other format reproducing or capturing any of the Protected Material. Whether
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the Protected Material is returned or destroyed, the Receiving Party must submit a
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written certification to the Producing Party (and, if not the same person or entity, to
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the Designating Party) by the 60 day deadline that (1) identifies (by category,
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where appropriate) all the Protected Material that was returned or destroyed and
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(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
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an archival copy of all pleadings, motion papers, trial, deposition, and hearing
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transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert
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reports, attorney work product, and consultant and expert work product, even if
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such materials contain Protected Material. Any such archival copies that contain
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or constitute Protected Material remain subject to this Protective Order as set forth
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in Section 4 (DURATION).
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IT IS SO ORDERED.
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Dated: March 24, 2016
Andrew J. Wistrich
United States Magistrate Judge
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EXHIBIT A
ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
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I, _____________________________ [print or type full name], of
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________________
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[print or type full address], declare under penalty of perjury that I have read in its
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entirety and understand the Stipulated Protective Order that was issued by the
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United States District Court for the Central District of California on [________] in
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the case of Brand Tarzana Surgical Institute, Inc. v. United Health Group, Inc., et
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al. Case No. 2:15-cv-09911-CBM (AJWx).
I agree to comply with and to be bound by all the terms of this Stipulated
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Protective Order and I understand and acknowledge that failure to so comply could
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expose me to sanctions and punishment in the nature of contempt. I solemnly
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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
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Court for the Central District of California for the purpose of enforcing the terms
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of this Stipulated Protective Order, even if such enforcement proceedings occur
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after termination of this action.
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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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[printed name]
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Signature: __________________________________
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[signature]
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PROOF OF SERVICE
STATE OF CALIFORNIA
COUNTY OF ORANGE
)
) ss
)
I am employed in the County of Orange, State of California. I am
over the age of 18 years and not a party to the within action. My business address
is 101 Enterprise, Suite 350, Aliso Viejo, CA 92656.
On March 25, 2016, I served the foregoing document(s) described as
[PROPOSED] STIPULATED PROTECTIVE ORDER
on all interested parties in this action as follows (or as on the attached service list):
RICHARD D. WILLIAMS
rwilliams@lwmpartners.com
MINA HAKAKIAN
mhakakian@lwmpartners.com
LYTTON WILLIAMS MESSINA & HANKIN LLP
1801 Century Park East, Suite 1450
Los Angeles, California 90067
BY CM/ECF NOTICE OF ELECTRONIC FILING: I electronically filed the
document(s) with the Clerk of the Court by using the CM/ECF system. Participants
in the case who are registered CM/ECF users will be served by the CM/ECF
system. Participants in the case who are not registered CM/ECF users will be
served by mail or by other means permitted by the court rules.
I declare under penalty of perjury under the laws of the State of
California that the above is true and correct.
Executed on March 25, 2016, at Aliso Viejo, California.
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Jessica M. Ridley
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