Thrash et al v. Cirrus Enterprises, LLC et al
Filing
78
STIPULATION AND ORDER re 77 STIPULATION WITH PROPOSED ORDER of Protective Order Re Export-Controlled and Confidential / Proprietary Documents and Information filed by United Technologies Corporation. Signed by Judge Jon S. Tigar on October 11, 2017. (wsn, COURT STAFF) (Filed on 10/11/2017)
1 TUCKER ELLIS LLP
Lance D. Wilson SBN 183852
2 lance.wilson tuckerellis.com
Fer m P. Rmz SBN 209258
3 ferlin.ruiz@tuckerellis.com
One Market Plaza
4 Steuart Tower, Suite 700
San Francisco, CA 94105
5 Telephone: 415.617.2400
Facsimile: 415.617.2409
6
TUCKER ELLIS LLP
7 Justin E. Garratt SBN 253520
justin.garratt@tuckerellis.com
8 515 South Flower Street
Forty-Second Floor
9 Los Angeles, CA 90071-2223
Telephone: 213.430.3400
Facsimile:
213.430.3409
Attorneys for Defendants
UNITED TECHNOLOGIES CORPORATION
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION
Case No.: 4:17-cv-01501
JOSEPH THRASH and CHEZ THRASH,
Plaintiffs,
19
v.
(PROPOSED) PROTECTIVE ORDER
RE: EXPORT-CONTROLLED AND
CONFIDENTIAL/PROPRIETARY
DOCUMENTS AND INFORMATION
CIRRUS ENTERPRISES, LLC, et al.,
20
Defendants.
21
22
23
24
25
1.
It is hereby ordered by the Court that the following shall apply to
26 information, documents, testimony, excerpts from documents, and other materials
27 produced in this action by the parties to this action pursuant to the Federal Rules of Civil
28 Procedure and the Local Civil Rules of the Northern District of California governing
1
1 disclosure and discovery.
2
2.
Information, testimony, documents and other materials may be designated
3 ("Designated Material") by any of the parties to this lawsuit, ("Designating Party(ies )")
4 in the manner permitted as set forth in this order. All such information, testimony,
5 documents, excerpts from ·documents, and other materials will constitute "Designated
6 Material" under this Order. The designations shall be (a) "CONFIDENTIAL"
7 ("Confidential"); (b) "SENSITIVE-SUBJECT TO EXPORT CONTROL-U.S. Arms
8 Export Act, International Traffic In Arms Regulations, Export Administration Act, U.S.
9 Export Administration Regulations," (hereafter: "Export-Controlled"); (c) "Limited
§
·u
~
10 Distribution"; and/or (d) "Proprietary."
11
3.
Documents shall be designated by stamping or otherwise marking the
documents with the words "CONFIDENTIAL," "SENSITIVE-SUBJECT TO EXPORT
CONTROL-U.S. Arms Export Act, International Traffic In Arms Regulations, Export
Administration Act, U.S. Export Administration Regulations," "Limited Distribution,"
and/or "Proprietary", thus clearly identifying the category of Designated Material for
which protection is sought under the terms of this Order. Depending on the nature and
substance of the document, Designating Parties may designate with more than one
"0
§
~ 18
u
designation under this order. Designated Material not reduced to documentary form shall
19 be designated by the producing party in a reasonably equivalent way.
20
21
4.
Nondisclosure of information designated as "CONFIDENTIAL":
a.
Information may be designated as "CONFIDENTIAL" if the
22
information constitutes (i) a trade secret as defined under law; (ii)
23
confidential business information, the disclosure of which might
24
adversely affect or prejudice business or competitive position of the
25
Designating Parties or any of their past or present subsidiaries,
26
affiliated companies, or divisions, within their trade or business; (iii)
27
non-public financial information relating to a Designating Party or any
28
of its present or past subsidiaries, affiliated companies, or divisions;
2
1
2
obligation to any other person to maintain in confidence; (v) any
3
information otherwise protected from disclosure by the applicable rules
4
of civil procedure and/or rules of evidence; or (vi) a Designating
5
Party's proprietary information. "CONFIDENTIAL" information will
6
mean and include information contained or disclosed in any materials, ·
7
including without limitation, documents, portions of documents,
8
answers to interrogatories, responses to requests for admissions, trial
9
g
(iv) non-public information which a Designating Party is under an
testimony, deposition testimony, and transcripts of trial testimony and
depositions, including data, summaries, and compilations derived
10
"'
-~ 11
therefrom that is designated as "CONFIDENTIAL" as set forth in this
~
§
~
"'
.....:l~
.....:l g!
~
r.rJ
Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.
Why Is My Information Online?