Securities And Exchange Commission v. Schroeder
Filing
174
STIPULATED PROTECTIVE ORDER re confidentiality of certain materials produced by non-party Wilson Sonsini Goodrich & Rosati re 172 STIPULATION AND [PROPOSED] PROTECTIVE ORDER. Signed by Magistrate Judge Howard R. Lloyd on 8/25/2009. (hrllc2, COURT STAFF) (Filed on 8/25/2009) Modified docket to create linkage on 8/26/2009 (ecg, COURT STAFF).
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DLA PIPER LLP (US)
SHIRLI FABBRI WEISS (Bar No. 079225) DAVID PRIEBE (Bar No. 148679) JEFFREY B. COOPERSMITH (Bar No. 252819) DLA PIPER LLP (US) 2000 University Avenue East Palo Alto, CA 94303-2248 Tel: (650) 833-2000 Fax: (650) 833-2001 Email: shirli.weiss@dlapiper.com Email: david.priebe@dlapiper.com Email: jeff.coopersmith@dlapiper.com ELLIOT R. PETERS (Bar No. 158708) STUART L. GASNER (Bar No. 164675) KEKER & VAN NEST LLP 710 Sansome Street San Francisco, CA 94111 Tel: (415) 391-5400 Fax: (415) 397-7188 Email: EPeters@KVN.com Email: SGasner@KVN.com Attorneys for Defendant KENNETH L. SCHROEDER
*ORDER E-FILED 8/25/2009*
UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION SECURITIES AND EXCHANGE COMMISSION Plaintiff, v. KENNETH L. SCHROEDER Defendant. No. C-07-3798-JW XXXXXXXXX STIPULATION AND [PROPOSED] PROTECTIVE ORDER REGARDING CONFIDENTIALITY OF CERTAIN MATERIALS PRODUCED BY NON-PARTY WILSON SONSINI GOODRICH & ROSATI
SEC v. SCHROEDER CASE NO. C-07-3798-JW
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STIPULATION AND PROTECTIVE ORDER
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DLA PIPER LLP (US)
STIPULATION WHEREAS, on June 17, 2009, defendant Kenneth L. Schroeder ("Schroeder") issued a subpoena to non-party Wilson Sonsini Goodrich & Rosati ("WSGR") (the "Subpoena"); WHEREAS, on July 7, 2009, Magistrate Judge Howard R. Lloyd entered the Protective Order Regarding Confidentiality of Certain Materials as to Which KLA-Tencor Corporation Claims Privilege (the "July 7, 2009 Protective Order"), having heard certain arguments regarding claims of privilege asserted by KLA-Tencor Corporation ("KLA"), among others; WHEREAS, based on the nature of a significant portion of the documents that WSGR ant icipates producing in response to the Subpoena, and the need for expeditious production of documents, the parties and WSGR agree that it is appropriate that WSGR's production of documents be governed by the July 7, 2009 Protective Order; Accordingly, WSGR, Schroeder, and the SEC hereby petition the Court to enter the following [Proposed] Protective Order Regarding Confidentiality of Certain Materials Produced by Wilson Sonsini Goodrich & Rosati ("Protective Order"); IT IS THEREFORE STIPULATED AND AGREED, by and between WSGR, Schroeder, and the SEC, through their respective counsel, as follows: By this Protective Order, the July 7, 2009 Protective Order shall be read to govern documents produced by WSGR during this litigation. Accordingly, each provision of the July 7, 2009 Protective Order shall apply to WSGR, to its production of documents, and to the parties' use and handling of documents produced by WSGR, including (but not limited to): 1. the definition of "Confidential Material" in paragraph 1.b. shall be read to include information or tangible things produced by WSGR or any of its current or former partners or employees; 2. the definition of "Material" in paragraph 1.d. shall be read to include documents, electronically stored information, testimony and discovery responses, including all copies, excerpts and summaries thereof produced by WSGR or any of its current or former partners or employees;
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DLA PIPER LLP (US)
3.
the definition of "Person" in paragraph 1.f. shall refer to and include WSGR or any of its current or former partners or employees; and
4.
paragraph 2 shall be read to govern the handling of all Material provided by WSGR or any of its current or former employees during this Action.
IT IS SO STIPULATED AND AGREED.
Dated: August 24, 2009
DLA PIPER LLP (US) By: /s/ Jeffrey B. Coopersmith Jeffrey B. Coopersmith Attorneys for Defendant KENNETH L. SCHROEDER
Dated: August 24, 2009
WILSON SONSINI GOODRICH & ROSATI Professio nal Corporation By: /s/ Dominique-Chantale Alepin Dominique-Chantale Alepin Attorneys for Non-Party WILSON SONSINI GOODRICH & ROSATI
Dated: August 24, 2009
SECURITIES AND EXCHANGE COMMISSION By: /s/ Susan F. LaMarca Susan F. LaMarca Attorneys for Plaintiff SECURITIES AND EXCHANGE COMMISSION
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DLA PIPER LLP (US)
[XXXXOXED] ORDER PROPX S XX IT IS SO ORDERED.
25 Dated: August __, 2009 HOWARD R. LLOYD United States Magistrate Judge
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