Naus v. Henry Schein, Inc.

Filing 19

STIPULATION and ORDER signed by Magistrate Judge Dale A. Drozd on 8/4/2009 GRANTING 16 Stipulation and Proposed Protective Order.(Matson, R)

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LITTLER MENDELSON
A PROFESSIONAL CORPORATION 5200 North Palm Avenue Suite 302 Fresno, CA 93704.2225 559.244.7500

Rayma Church, No. 154897 E-Mail: [e-mail] LAW OFFICES OF EMERSON, COREY, SORENSEN, CHURCH & YOHMAN 2520 WEST SHAW LANE, Suite 102 FRESNO, CALIFORNIA 93711-2765 Telephone [phone] Facsimile [phone] Attorneys for Plaintiff, HOLLY NAUS DANIEL J. CRAVENS, Bar No. 207859 E-Mail: [e-mail] KHATEREH SAGE FAHIMI, Bar No. 252152 E-Mail: [e-mail] LITTLER MENDELSON A Professional Corporation 5200 North Palm Avenue, Suite 302 Fresno, CA 93704.2225 Telephone: [phone] Facsimile: 559.244.7525 Attorneys for Defendant HENRY SCHEIN, INC. UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA

HOLLY NAUS, Plaintiff, v. HENRY SCHEIN, INC., Defendant.

Case No. 2:08-CV-02497-LKK-DAD
STIPULATION AND ORDER RE: PROTECTIVE ORDER

Subject to the approval of this Court, the parties hereby stipulate to the following protective order: 1. In connection with discovery proceedings in this action, the parties may

designate any document, thing, material, testimony or other information derived therefrom, as "Confidential" under the terms of this Stipulated Protective Order (hereinafter "Order"). Confidential information is information which has not been made public and which concerns or
(CASE NO. 2:08-CV-02497-LKK-DAD)

Stipulation and Order Re: Protective Order

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relates to the processes, operations, type or work, or apparatus, or to the production, sales, shipments, purchases, transfers, identification of customers, inventories, amount or source of any income, profits, losses, or expenditures of any persons, firm, partnership, corporation, or other organization, the disclosure of which information may have the effect of causing harm to the competitive position of the person, firm, partnership, corporation, or to the organization from which the information was obtained. 2. By designating a document, thing, material, testimony or other information

derived therefrom as "confidential," under the terms of this order, the party making the designation is certifying to the court that there is a good faith basis both in law and in fact for the designation within the meaning of Federal Rule of Civil Procedure 26(g). Confidential documents shall be so designated by stamping copies of the document produced to a party with the legend "CONFIDENTIAL." Stamping the legend "CONFIDENTIAL" on the cover of any multi-page document shall designate all pages of the document as confidential, unless otherwise indicated by the producing party. 3. Testimony taken at a deposition, conference, hearing or trial may be

designated as confidential by making a statement to that effect on the record at the deposition or other proceeding. Arrangements shall be made with the court reporter taking and transcribing such proceeding to separately bind such portions of the transcript containing information designated as confidential, and to label such portions appropriately. 4. Material designated as confidential under this Order, the information

contained therein, and any summaries, copies, abstracts, or other documents derived in whole or in part from material designated as confidential (hereinafter "Confidential Material") shall be used only for the purpose of the prosecution, defense, or settlement of this action, and for no other purpose. /// /// /// /// ///
(CASE NO. 2:08-CV-02497-LKK-DAD)

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STIPULATION AND ORDER RE: PROTECTIVE ORDER

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5.

Confidential Material produced pursuant to this Order may be disclosed or

made available only to the Court, to counsel for a party (including the paralegal, clerical, and secretarial staff employed by such counsel) and expert witnesses retained by a party.

Dated: July 22, 2009 /s/ RAYMA CHURCH EMERSON, COREY, SORENSEN, CHURCH & YOHMAN Attorneys for Plaintiff, HOLLY NAUS

Dated: July 29, 2009 /s/ DANIEL J. CRAVENS LITTLER MENDELSON A Professional Corporation Attorneys for Defendant HENRY SCHEIN, INC.

PURSUANT TO STIPULATION, IT IS SO ORDERED.

Dated: August 4, 2009.
______________________________________ DALE A. DROZD UNITED STATES MAGISTRATE JUDGE

Ddad1/orders.civil/naus2497.protectord

Firmwide:90873852.1 052225.1034

(CASE NO. 2:08-CV-02497-LKK-DAD)

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STIPULATION AND ORDER RE: PROTECTIVE ORDER