IV Solutions, Inc. v. Pacificare Life and Health Insurance Company et al
Filing
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PROTECTIVE ORDER GOVERNING THE PRODUCTION AND EXCHANGE OF CONFIDENTIAL INFORMATION by Magistrate Judge Michael R. Wilner. (See Order for details) re Stipulation for Protective Order 27 (vm)
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UNITED STATES DISTRICT COURT
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CENTRAL DISTRICT OF CALIFORNIA
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WESTERN DIVISION
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IV SOLUTIONS, INC., a California
corporation,
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Plaintiff,
v.
PACIFICARE LIFE AND HEALTH
INSURANCE COMPANY, an Indiana
corporation; and DOES 1 - 30, inclusive,
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Case No. 2:16-cv-07153-SJO-MRWx
STIPULATED PROTECTIVE
ORDER GOVERNING THE
PRODUCTION AND EXCHANGE
OF CONFIDENTIAL
INFORMATION
Hon. James Otero
Department 1 (1st Street)
Defendants.
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STIPULATED PROTECTIVE ORDER;
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1.
INTRODUCTION
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1.1
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Discovery in this action is likely to involve production of confidential,
PURPOSES AND LIMITATIONS
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proprietary, or private information for which special protection from public
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disclosure and from use for any purpose other than prosecuting this litigation may
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be warranted. Accordingly, the parties hereby stipulate to and petition the Court to
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enter the following Stipulated Protective Order. The parties acknowledge that this
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Order does not confer blanket protections on all disclosures or responses to
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discovery and that the protection it affords from public disclosure and use extends
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only to the limited information or items that are entitled to confidential treatment
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under the applicable legal principles. The parties further acknowledge, as set forth
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in Section 12.3, below, that this Stipulated Protective Order does not entitle them to
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file confidential information under seal; Civil Local Rule 79-5 sets forth the
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procedures that must be followed and the standards that will be applied when a
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party seeks permission from the court to file material under seal.
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1.2
GOOD CAUSE STATEMENT
This case involves allegations by Plaintiff IV Solutions, Inc. (“IVS”)
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that defendant PacifiCare Life and Health Insurance Company (“PLHIC”) failed to
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pay IVS its full billed charges for medical services provided by IVS to PLHIC’s
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member “C.M.” (whose identity is protected herein from disclosure). Discovery in
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this case will naturally contain information regarding C.M., C.M.’s medical
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condition, and medical services provided by IVS to C.M., all of which is protected
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by the Health Insurance Portability and Accountability Act (“HIPAA”). The parties
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must ensure this information is kept confidential. Discovery in this case is also
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likely to seek production of information regarding the parties’ trade secret,
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privileged, proprietary or confidential information, including, without limitation,
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the sources of certain drugs provided to C.M. for her treatment and the prices paid
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for such drugs.
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2.
DEFINITIONS
2.1
Action: IV Solutions, Inc. v. PacifiCare Life and Health
Insurance Company, case number 2:16-cv-07153-SJO-MRW.
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
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(regardless of how it is generated, stored or maintained) or tangible things that
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qualify for protection under Federal Rule of Civil Procedure 26(c), and as specified
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above in the Good Cause Statement.
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2.4
“HIGHLY CONFIDENTIAL” Information or Items: any
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Confidential information that any Party determines in good faith is particularly
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sensitive, confidential, personal, and/or private, and/or the disclosure of which to
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persons other than those set forth in Section 7.3 below is reasonably likely to cause
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serious competitive harm or other harm.
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2.5
Counsel: 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
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information or items that it produces in disclosures or in responses to discovery as
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“CONFIDENTIAL” or “HIGHLY CONFIDENTIAL.”
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2.7
Disclosure or Discovery Material: all items or information,
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regardless of the medium or manner in which it is generated, stored, or maintained
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(including, among other things, testimony, transcripts, and tangible things), that are
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produced or generated in disclosures or responses to discovery in this matter.
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2.8
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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2.9
House Counsel: attorneys who are employees of a party to this
Action. House Counsel does not include Outside Counsel of Record or any other
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outside counsel.
2.10 Non-Party: any natural person, partnership, corporation,
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association, or other legal entity not named as a Party to this action.
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2.11 Outside Counsel of Record: attorneys who are not employees of
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a party to this Action but are retained to represent or advise a party to this Action
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and have appeared in this Action on behalf of that party or are affiliated with a law
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firm which has appeared on behalf of that party, and includes support staff.
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2.12 Party: any party to this Action, including all of its officers,
directors, employees, consultants, retained experts, and Outside Counsel of Record
(and their support staffs).
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2.13 Producing Party: a Party or Non-Party that produces Disclosure
or Discovery Material in this Action.
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2.14 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.
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2.15 Protected Material: any Disclosure or Discovery Material that is
designated as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL.”
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2.16 Receiving Party: a Party that receives Disclosure or Discovery
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Material from a Producing Party.
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3.
SCOPE
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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
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extracted from Protected Material; (2) all copies, excerpts, summaries, or
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compilations of Protected Material; and (3) any testimony, conversations, or
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presentations by Parties or their Counsel that might reveal Protected Material.
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Any use of Protected Material at trial will be governed by the orders of the
trial judge. This Order does not govern the use of Protected Material at trial.
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4.
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DURATION
Even after final disposition of this litigation, the confidentiality obligations
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imposed by this Order will remain in effect until a Designating Party agrees
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otherwise in writing or a court order otherwise directs. Final disposition will 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 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
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this Order must take care to limit any such designation to specific material that
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qualifies under the appropriate standards. The Designating Party must designate for
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protection only those parts of material, documents, items, or oral or written
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communications that qualify so that other portions of the material, documents,
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items, or communications for which protection is not warranted are not swept
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unjustifiably within the ambit of this Order.
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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
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impose unnecessary expenses and burdens on other parties) may expose the
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Designating Party 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
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.
Designation in conformity 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 at a minimum, the legend
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“CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”) or “HIGHLY
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CONFIDENTIAL” (hereinafter “HIGHLY CONFIDENTIAL” legend), to each
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page that contains protected material. If only a portion or portions of the material on
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a 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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A Party or Non-Party that makes original documents available for inspection
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need not designate them for protection until after the inspecting Party has indicated
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which documents it would like copied and produced. During the inspection and
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before the designation, all of the material made available for inspection will be
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deemed “CONFIDENTIAL legend” or “HIGHLY CONFIDENTIAL” legend After
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the inspecting Party has identified the documents it wants copied and produced, the
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Producing Party must determine which documents, or portions thereof, qualify for
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protection under this Order. Then, before producing the specified documents, the
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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 page
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qualifies 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).
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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 on
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the exterior of the container or containers in which the information is stored the
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legend “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL.” If only a portion or
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portions of the information warrants protection, the Producing Party, to the extent
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practicable, will identify the protected portion(s).
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Inadvertent Failures to Designate. If timely corrected, an
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inadvertent failure to designate qualified information or items does not, standing
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alone, waive the Designating Party’s right to secure protection under this Order for
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such material. Upon timely correction of a designation, the Receiving Party must
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make reasonable efforts to assure that the material is treated in accordance with the
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provisions of this Order.
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6.
CHALLENGING CONFIDENTIALITY DESIGNATIONS
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6.1
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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6.2
Meet and Confer. The Challenging Party will initiate the dispute
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resolution process (and, if necessary, file a discovery motion) under Local Rule
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37.1 et seq.
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6.3
The burden of persuasion in any such challenge proceeding will
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be on the Designating Party. Frivolous challenges, and those made for an improper
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purpose (e.g., to harass or impose unnecessary expenses and burdens on other
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parties) may expose the Challenging Party to sanctions. Unless the Designating
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Party has waived or withdrawn the confidentiality designation, all parties will
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continue to afford the material in question the level of protection to which it is
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entitled under the Producing Party’s designation until the Court rules on the
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challenge.
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7.
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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
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Receiving Party must comply with the provisions of section 13 below (FINAL
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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
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“CONFIDENTIAL” 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)
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 have
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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;
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(h)
during their depositions, witnesses, and attorneys for witnesses, in the
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Action to whom disclosure is reasonably necessary provided: (1) the deposing party
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requests that the witness sign the form attached as Exhibit A hereto; and (2) they
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will not be permitted to keep any confidential information unless they sign the
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“Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
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agreed by the Designating Party or ordered by the court. Pages of transcribed
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deposition testimony or exhibits to depositions that reveal Protected Material may
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be separately bound by the court reporter and may not be disclosed to anyone
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except as permitted under this Stipulated Protective Order; and
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(i)
any mediator or settlement officer, and their supporting personnel,
mutually agreed upon by any of the parties engaged in settlement discussions.
7.3
Disclosure of “HIGHLY CONFIDENTIAL” Information or Items.
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Unless otherwise ordered by the court or permitted in writing by the Designating
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Party, a Receiving Party may disclose any information or item designated
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“HIGHLY CONFIDENTIAL” 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 have
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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
custodian or other person who otherwise possessed or knew the information;
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(g)
during their depositions, witnesses, and attorneys for witnesses, in the
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Action to whom disclosure is reasonably necessary provided: (1) the deposing party
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requests that the witness sign the form attached as Exhibit A hereto; and (2) they
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will not be permitted to keep any confidential information unless they sign the
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“Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
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agreed by the Designating Party or ordered by the court. Pages of transcribed
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deposition testimony or exhibits to depositions that reveal Protected Material may
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be separately bound by the court reporter and may not be disclosed to anyone
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except as permitted under this Stipulated Protective Order; and
(h)
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any mediator or settlement officer, and their supporting personnel,
mutually agreed upon by any of the parties engaged in settlement discussions.
(i)
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designated in-house counsel of the Receiving Party (including in-
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house counsel’s support staff) (1) who has no involvement in competitive decision-
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making, (2) to whom disclosure is reasonably necessary for this litigation, and (3)
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who has signed the “Acknowledgement And Agreement To Be Bound” (Exhibit
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A).
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8.
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IN OTHER LITIGATION
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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 or items designated in this Action as
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“CONFIDENTIAL,” or “HIGHLY CONFIDENTIAL” that Party must:
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(a)
promptly notify in writing the Designating Party. Such notification
will include a copy of the subpoena or court order;
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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 will include
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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 the Designating Party timely seeks a protective order, the Party served with
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the subpoena or court order will not produce any information designated in this
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action as “CONFIDENTIAL” or “HIGHLY 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. The Designating Party will
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bear 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” or “HIGHLY
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CONFIDENTIAL.” Such information produced by Non-Parties in connection with
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this 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 from
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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 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 will:
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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 confidentiality
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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 reasonably
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specific description of the information requested; and
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(3)
make the information requested available for inspection by the
Non-Party, if requested.
(c)
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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 Party
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may produce the Non-Party’s confidential information responsive to the discovery
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request. If the Non-Party timely seeks a protective order, the Receiving Party will
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not produce any information in its possession or control that is subject to the
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confidentiality agreement with the Non-Party before a determination by the court.
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Absent a court order to the contrary, the Non-Party will bear the burden and
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expense of seeking protection in this court of its Protected Material.
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10.
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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
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efforts to retrieve all unauthorized copies of the Protected Material, (c) inform the
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person or persons to whom unauthorized disclosures were made of all the terms of
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this Order, and (d) request such person or persons to execute the “Acknowledgment
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and 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
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protection, the obligations of the Receiving Parties are those set forth in Federal
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Rule of Civil Procedure 26(b)(5)(B). This provision is not intended to modify
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whatever procedure may be established in an e-discovery order that provides for
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production without prior privilege review. Pursuant to Federal Rule of Evidence
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502(d) and (e), insofar as the parties reach an agreement on the effect of disclosure
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of a communication or information covered by the attorney-client privilege or work
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product protection, the parties may incorporate their agreement in the stipulated
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protective order submitted to the court.
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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. By stipulating to the entry of this
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Protective Order no Party waives any right it otherwise would have to object to
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disclosing or producing any information or item on any ground not addressed in
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this Stipulated Protective Order. Similarly, no Party waives any right to object on
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any ground to use in evidence of any of the material covered by this Protective
12
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
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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. 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
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in the public record unless otherwise instructed by the court.
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13.
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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
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return all Protected Material to the Producing Party or destroy such material. As
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used in this subdivision, “all Protected Material” includes all copies, abstracts,
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compilations, summaries, and any other format reproducing or capturing any of the
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Protected Material. Whether the Protected Material is returned or destroyed, the
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Receiving Party must submit a written certification to the Producing Party (and, if
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not the same person or entity, to the Designating Party) by the 60 day deadline that
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(1) identifies (by category, where appropriate) all the Protected Material that was
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returned or destroyed and (2) affirms that the Receiving Party has not retained any
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copies, abstracts, compilations, summaries or any other format reproducing or
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capturing any of the Protected Material. Notwithstanding this provision, Counsel
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are entitled to retain an archival copy of all pleadings, motion papers, trial,
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deposition, and hearing transcripts, legal memoranda, correspondence, deposition
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and trial exhibits, expert reports, attorney work product, and consultant and expert
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work product, even if such materials contain Protected Material. Any such archival
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copies that contain or constitute Protected Material remain subject to this Protective
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Order as set forth in Section 4 (DURATION).
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14.
Any willful violation of this Order may be punished by civil or criminal
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contempt proceedings, financial or evidentiary sanctions, reference to disciplinary
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authorities, or other appropriate action at the discretion of the Court.
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IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
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DATED: June 7, 2017
WOLF, RIFKIN, SHAPIRO, SCHULMAN &
RABKIN, LLP
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By
/s/ Eric Levinard
Marc E. Rohatiner
Eric Levinard
Attorneys for Plaintiff IV Solutions, Inc.
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DATED: June 7, 2017
CROWELL & MORING LLP
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By
/s/ Daniel M. Glassman
Jennifer S. Romano
Daniel M. Glassman
Attorneys for Defendant PacifiCare Life
and Health Insurance Company
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C ROWELL
& M ORING LLP
-13-
ATTO RNEY S AT LAW
LAACTIVE-602737855-1
STIPULATED PROTECTIVE ORDER;
CASE NO. 2:16-CV-07153-SJO-MRW
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FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
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June 7, 2017
DATED:_______________
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________________________________
HON. MICHAEL R. WILNER
United States Magistrate Judge
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C ROWELL
& M ORING LLP
-14-
ATTO RNEY S AT LAW
LAACTIVE-602737855-1
STIPULATED PROTECTIVE ORDER;
CASE NO. 2:16-CV-07153-SJO-MRW
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EXHIBIT A
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ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND
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I, _____________________________ [full name], of _________________
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[full address], declare under penalty of perjury that I have read in its entirety and
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understand the Stipulated Protective Order that was issued by the United States
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District Court for the Central District of California on [_____] in the case of IV
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Solutions, Inc. v. PacifiCare Life and Health Insurance Company, case number
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2:16-CV-07153-SJO-MRW. I agree to comply with and to be bound by all the
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terms of this Stipulated Protective Order and I understand and acknowledge that
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failure to so comply could expose me to sanctions and punishment in the nature of
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contempt. I solemnly promise that I will not disclose in any manner any
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information or item that is subject to this Stipulated Protective Order to any person
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or entity except in strict 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 __________________________ [full
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name] of _______________________________________ [full address and
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telephone number] as my California agent for service of process in connection
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with this action or any proceedings related to enforcement of this Stipulated
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Protective Order.
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Date: ______________________________________
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City and State where signed: _________________________________
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Printed name: _______________________________
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Signature: __________________________________
C ROWELL
& M ORING LLP
-15-
ATTO RNEY S AT LAW
LAACTIVE-602737855-1
STIPULATED PROTECTIVE ORDER;
CASE NO. 2:16-CV-07153-SJO-MRW
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I, Daniel M. Glassman, am the ECF user whose ID and password are
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being used to file this document. In compliance with General Order 45, section
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X.B., I hereby attest that concurrence in the filing of the document has been
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obtained from each of the other signatories.
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By:
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/s/ Daniel M. Glassman
Daniel M. Glassman
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C ROWELL
& M ORING LLP
-16-
ATTO RNEY S AT LAW
LAACTIVE-602737855-1
STIPULATED PROTECTIVE ORDER;
CASE NO. 2:16-CV-07153-SJO-MRW
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CERTIFICATE OF SERVICE
Pursuant to Rule 5-3 of the Local Civil Rules of the United States District
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Court for the Central District of California, I hereby certify under penalty of perjury
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under the laws of the United States of America that on June 6, 2017, a true copy of
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the above document was filed through the Court’s Electronic Case Filing system
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and served by that system upon all counsel of record registered for the system and
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deemed to have consented to electronic service in the above-captioned case.
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Dated:
June 6, 2017
CROWELL & MORING LLP
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/s/ Daniel M. Glassman
Daniel M. Glassman
Attorneys for Defendant
PACIFICARE LIFE AND HEALTH
INSURANCE COMPANY
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C ROWELL
& M ORING LLP
-17-
ATTO RNEY S AT LAW
LAACTIVE-602737855-1
STIPULATED PROTECTIVE ORDER;
CASE NO. 2:16-CV-07153-SJO-MRW
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