Starcrest Products of California Inc v. Publishers Clearing House LLC et al

Filing 350

STIPULATED PROTECTIVE ORDER by Judge Virginia A. Phillips re Stipulation for Protective Order 349 . (See document for specifics) (mrgo)

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UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA ) Case No. EDCV04-0605 VAP (SGLx) ) ) STIPULATED PROTECTIVE ) ORDER Plaintiff, ) vs. ) ) PUBLISHERS CLEARING HOUSE, a ) New York limited partnership, ) ) Defendants. ) ________________________________ ) ) ) and RELATED COUNTERCLAIM ) ) Pursuant to the stipulation in this matter among plaintiff and counterdefendant

CALIFORNIA, INC., a Delaware 12 Corporation,
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21 STARCREST PRODUCTS OF CALIFORNIA, INC., defendant and 22 counterclaimant PUBLISHERS CLEARING HOUSE LLC, MILLENNIUM 23 CORPORATE SOLUTIONS, INC. ("MILLENNIUM") and LEXINGTON 24 INSURANCE COMPANY ("LEXINGTON") ("the Stipulation"), the Court makes 25 the following order: 26 1. Pursuant to Paragraph 12, Subsection (b), of the December 17, 2004 27 28
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Stipulated Protective Order and Paragraph 11, Subsection (b) of the

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May 31, 2005 Protective Order of Publishers Clearing House LLC Re: Financial Documents, MILLENNIUM and LEXINGTON and their respective outside attorneys are designated as persons who may receive information stamped CONFIDENTIAL, said outside attorneys may receive information stamped CONFIDENTIAL ATTORNEYS-EYES ONLY and/or CONFIDENTIAL ATTORNEYS ONLY, and up to 5 said outside attorneys may receive information stamped HIGHLY CONFIDENTIAL FINANCIAL INFORMATION: ATTORNEYS EYES ONLY/COPY CONTROLLED (Copy No. __). 2. MILLENNIUM and LEXINGTON and their respective outside attorneys will be bound by each and every one of the provisions of the December 17, 2004 Stipulated Protective Order and the May 31, 2005 Protective Order of Publishers Clearing House LLC Re: Financial Documents as fully as if they had been original parties to this case and subject to those protective orders. 3. Notwithstanding anything contained in the foregoing or those protective orders, MILLENNIUM and LEXINGTON and their respective outside attorneys waive, and agree that they will not seek to enforce, any right to contest the designation of any document or item of information obtained by virtue of the Stipulation as confidential or to seek the further amendment, modification or vacation of either of the December 17, 2004 Stipulated Protective Order or the May 31, 2005 Protective Order of Publishers Clearing House LLC Re: Financial Documents. 4. MILLENNIUM and LEXINGTON and their respective outside attorneys subject themselves to the jurisdiction of the Court for the purpose of enforcing compliance with the Stipulation and the
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December 17, 2004 Stipulated Protective Order and the May 31, 2005 Protective Order of Publishers Clearing House LLC Re: Financial Documents.

Dated: November 18, 2009

By: _______________________________ HON. VIRGINIA A. PHILLIPS U.S. DISTRICT JUDGE

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