B&H Manufacturing Company Inc. v. Sidel, Inc.

Filing 89

STIPULATED PROTECTIVE ORDER re Confidential Information signed by Magistrate Judge Edmund F. Brennan on 4/20/09. (Duong, D)

Steven M. Levitan (State Bar No. 148716) 1 R. Scott Feldmann (State Bar No. 169230) (admission application pending) Jennifer M. Lantz (State Bar No. 202252) Inchan A. Kwon (State Bar No. 247614) 2 Jonathan M. Lindsay (State Bar No. 208840) (admission application pending) HAYNES AND BOONE, LLP 2033 Gateway Place, Suite 400 3 Thomas E. Dietrich (State Bar No. 254282) CROWELL & MORING LLP San Jose, California 95110 Telephone: [phone] Park Plaza, 20th Floor Irvine, California 92614-8505 Facsimile: [phone] 5 Telephone: [phone] Facsimile: [phone] 6 Co-counsel for Plaintiff and Counterclaim Defendant 7 B&H MANUFACTURING COMPANY, INC. 8 John B. Scherling (State Bar No. 122234) Scott H. Davison (State Bar No. 228807) 9 SUGHRUE MION, PLLC 501 West Broadway, Suite 1600 10 San Diego, California 92101 Telephone: [phone] Facsimile: [phone] 12
3 Park Plaza, 20th Floor Irvine, CA 92614-8505 [phone]

Mark Boland (admitted pro hac vice) Raja N. Saliba (admitted pro hac vice) Brian K. Shelton (admitted pro hac vice) SUGHRUE MION, PLLC 2100 Pennsylvania Avenue, N.W. Washington, D.C. 20037 Telephone: [phone] Facsimile: [phone]

Attorneys for Defendant and Counterclaimant 13 SIDEL, INC. 14 15 16 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA, SACRAMENTO DIVISION CASE NO. 2:07-CV-02208 MCE EFB STIPULATION AND ORDER RE: PARTIES' STIPULATED PROTECTIVE ORDER FOR THE PROTECTION OF CONFIDENTIAL INFORMATION

17 B&H MANUFACTURING COMPANY, INC., a California corporation doing business 18 as "B&H Labeling Systems," 19 20 v. Plaintiff,

21 SIDEL, INC., a Georgia Corporation, 22 23 24 / / / 25 / / / 26 / / / 27 / / / 28 / / /
Case No. 2:07-CV-02208 MCE EFB STIPULATION AND ORDER RE: PARTIES' STIPULATED PROTECTIVE ORDER

Defendant.

1

Pursuant to General Local Rule 83-143, the parties hereby stipulate that the Stipulated

2 Protective Order for the Protection of Confidential Information (the "Protective Order") which has 3 been entered in this action and which governs the handling by both parties and their counsel of 4 confidential business information produced in this action will be deemed to apply also to Crowell 5 & Moring LLP as B&H Manufacturing Company, Inc.'s ("B&H") co-counsel. The parties further 6 agree that any specific references in the Protective Order to the law firms of MacPherson, Kwok, 7 Chen & Heid, LLP or Haynes and Boone, LLP will be interpreted to refer also to Crowell & 8 Moring LLP. B&H's original counsel, MacPherson, Kwok, Chen & Heid, LLP merged with 9 another firm and became known as Haynes and Boone, LLP. Further, Crowell & Moring LLP has 10 been retained by B&H to serve as co-counsel for B&H, together with Haynes and Boone, LLP. 11 However, the Stipulated Protective Order at present makes no provision for access to confidential 12 information by Crowell & Moring LLP. Hence, the parties agree as to the need to enter into the 13 above-described stipulation.
3 Park Plaza, 20th Floor Irvine, CA 92614-8505 [phone]

14 15 CROWELL & MORING LLP 16 17 By: /s/ Thomas E. Dietrich Thomas E. Dietrich R. Scott Feldmann 18 Jonathan M. Lindsay 19 Co-counsel for Plaintiff and Counterdefendant 20 B&H MANUFACTURING COMPANY, INC. 21 22 23 SO ORDERED 24 DATED: April 20, 2009 25 26 27 28 IR4192986.2
Cam No. 105307.002

SUGHRUE MION PLLC

By: /s/ John B. Scherling John B. Scherling (as authorized on April 16, 2009) Attorneys for Defendant and Counterclaimant SIDEL, INC.

HON. EDMUND F. BRENNAN UNITED STATES MAGISTRATE JUDGE

Case No. 2:07-CV-02208 MCE EFB 1 STIPULATION AND [PROPOSED] ORDER RE: PARTIES' STIPULATED PROTECTIVE ORDER