Mechanical Marketing, Inc v. Sixxon Precision Machinery Co, Ltd et al
Filing
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STIPULATED PROTECTIVE ORDER re 62 Stipulation filed by Sixxon Precision Machinery Co, Ltd. Signed by Judge Paul S. Grewal on December 30, 2011. (psglc1, COURT STAFF) (Filed on 12/30/2011)
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WANG, HARTMANN, GIBBS & CAULEY, PLC
John van Loben Sels (State Bar No. 201354)
jvanlobensels@whgclaw.com
Kenneth A. Ohashi (State Bar No. 230440)
kohashi@whgclaw.com
2570 West El Camino Real, Suite 440
Mountain View, California 94040
Telephone Number: (650) 209-1230
Attorney for Defendant/Counter-claimant,
SIXXON PRECISION MACHINERY CO., LTD..
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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SAN JOSE DIVISION
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MECHANICAL MARKETING, INC., a
California Corporation,
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Plaintiff,
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CASE NO. 5: CV 11-01844 EJD PSG
STIPULATION AND [PROPOSED]
ORDER FOR PROTECTIVE ORDER
v.
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SIXXON PRECISION MACHINERY
CO., LTD.,
Defendant.
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Defendant/Counter-claimant Sixxon Precision Machinery Co., Ltd., Plaintiff/Counter22
defendant Mechanical Marketing, Inc., and Counter-defendants Arnold Dolgins and Carol Dolgins,
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by and through their respective counsel, have stipulated to a Stipulated Protective Order. They
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hereby file this stipulation regarding the Stipulated Protective Order. The Stipulated Protective
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Order is attached hereto as Exhibit “1”.
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1
STIPULATION AND [PROPOSED] ORDER FOR PROTECTIVE ORDER
EXHIBIT 1
EXHIBIT 1
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WANG, HARTMANN, GIBBS & CAULEY, PLC
John van Loben Sels (State Bar No. 201354)
jvanlobensels@whgclaw.com
Kenneth A. Ohashi (State Bar No. 230440)
kohashi@whgclaw.com
2570 West El Camino Real, Suite 440
Mountain View, California 94040
Telephone Number: (650) 209-1230
Attorney for Defendant/Counter-claimant,
SIXXON PRECISION MACHINERY CO., LTD..
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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SAN JOSE DIVISION
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MECHANICAL MARKETING, INC., a
California Corporation,
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Plaintiff,
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CASE NO. 5: CV 11-01844 EJD PSG
STIPULATED PROTECTIVE ORDER
v.
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SIXXON PRECISION MACHINERY
CO., LTD.,
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Defendant.
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1.
This Protective Order shall govern, and shall be applied on a narrowly-tailored basis
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to protect only documents, materials, items, or information that materially consist of information
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that is lawfully entitled to confidential treatment under the Federal Rules of Civil Procedure,
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including but not limited to commercially sensitive financial records of parties or third parties and
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employment or personnel files of third parties to this action.
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STIPULATED PROTECTIVE ORDER
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2.
As a general guideline, “Confidential Information” shall be used to designate those
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things that may be disclosed to the parties for the purposes of this litigation, but which must be
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protected against disclosure to third parties including documents, interrogatory responses, responses
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to requests for admission, deposition transcripts, or other information. Absent a specific order by
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the Court, once designated as “Confidential,” such information shall be used by the parties solely in
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connection with this litigation, and not for any business or competitive purpose or function, and
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such information shall not be disclosed to anyone except provided herein.
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3.
Absent written agreement of the designating party or a specific order by the Court,
once designated as “Confidential- Attorneys’ Eyes Only,” such designated information shall be
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used by the parties solely in connection with this litigation, and not for any business or competitive
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purpose or function, and such information shall not be disclosed to anyone except as provided
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herein.
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4.
Without written permission from the designating party or a court order secured after
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appropriate notice to all interested persons, a party may not file in the public record in this action
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any Confidential Information. A party that seeks to file under seal any Confidential Information
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must comply with Civil Local Rule 79-5 and General Order 62. Confidential Information may only
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be filed under seal pursuant to a court order authorizing the sealing of the specific Confidential
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Information at issue.
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5.
Pursuant to Civil Local Rule 79-5 and General Order 62, a sealing order will issue
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only upon a request establishing that the Confidential Information at issue is privileged, protectable
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as a trade secret, or otherwise entitled to protection under the law. If a receiving party’s request to
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file Protected Material under seal pursuant to Civil Local Rule 79-5(d) and General Order 62 is
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denied by the court, then the receiving party may file the information in the public record pursuant
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to Civil Local Rule 79-5(e) unless otherwise instructed by the court.
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6.
Parties submitting purportedly Confidential Information to the Court shall endeavor
in good faith to restrict their filings or other submissions to Confidential Information that is
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STIPULATED PROTECTIVE ORDER
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reasonably necessary for the Court to consider in connection with the issue or matter for which the
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Confidential Information is submitted.
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7.
The designation of information or material as “Confidential” or ‘Confidential —
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Attorneys’ Eyes Only” for purposes of this Protective Order shall be made in the following manner
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by the party or non-party seeking protection:
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a)
in the case of documents, exhibits, briefs, memoranda, interrogatory
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responses, responses to requests for admission, or other materials (apart from depositions or other
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pretrial or trial testimony): by affixing the legend “CONFIDENTIAL” or “CONFIIDENTIAL —
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ATTORNEYS’ EYES ONLY,” as appropriate, to any document containing any confidential
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information or material at the time such documents are produced or such information is disclosed,
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or as soon thereafter as the party or non-party seeking protection becomes aware of the confidential
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nature of the information or material disclosed and sought to be protected hereunder, and
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b)
in the case of depositions or other pretrial testimony: (i) by a statement on
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the record, by counsel, during such deposition or other pretrial proceeding that the entire transcript
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or a portion thereof shall be designated as “Confidential’ or Confidential — Attorneys’ Eyes Only,”
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as appropriate, hereunder, or (ii) by written notice of such designation sent by counsel to counsel
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for all other parties within thirty (30) days after the receipt by counsel of the transcript of the
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deposition or other pretrial proceeding. The parties shall treat all deposition and other pretrial
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testimony as “Confidential — Attorneys’ Eyes Only” hereunder until the expiration of thirty (30)
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days after the receipt by counsel of the transcript of the deposition or other pretrial proceeding.
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Unless so designated, any confidentiality is waived after the expiration of the 30-day period unless
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designated in writing as set forth above or otherwise stipulated or ordered. The parties may modify
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this procedure for any particular deposition or proceeding through agreement on the record at such
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deposition or proceeding or otherwise by written agreement, without further order of the Court. If
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any document or information designated as “Confidential” or “Confidential - Attorneys’ Eyes
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Only” is used during the course of a deposition or other pretrial proceeding, that portion of the
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deposition or pretrial proceeding record reflecting such confidential information shall be sealed and
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STIPULATED PROTECTIVE ORDER
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stamped with the designated degree of confidentiality, and access thereto shall be limited pursuant
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to the other terms of this Protective Order.
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c)
The protection of Confidential Information at trial shall be subject to
further order of this Court.
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8.
Information or material designated as “Confidential,” or copies or extracts therefrom
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and compilations and summaries thereof, may be disclosed, summarized, described, characterized,
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or otherwise communicated or made available in whole or in part only to the following persons:
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a)
employees of such counsel to whom it is necessary that the information or material be shown for
the purposes of this litigation;
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b)
parties and employees of the parties whose assistance is needed by counsel
for the purposes of this litigation, subject to and in compliance with Paragraph 11 herein;
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parties’ outside counsel of record in this action and regular and temporary
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consultants as defined in Paragraph 10 herein and subject to and conditioned
upon compliance with Paragraph 11 herein;
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d)
the Court;
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e)
court reporters and videographers employed in connection with this action;
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f)
graphics or design services retained by counsel for a party for purposes of
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preparing demonstrative or other exhibits for deposition, trial, or other court proceedings in this
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action;
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g)
jury or trial consulting services retained by counsel for a party; and
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h)
any other person only upon order of the Court or upon prior written consent
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of the party producing the confidential information or material, subject to and conditioned upon
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compliance with Paragraph 10 herein. Within thirty days after the final settlement or termination of
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this action, anyone receiving Designated Material must return or destroy any other party’s
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Designated Material, including all copies, extracts and summaries thereof, except that counsel for a
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party receiving Designated Materials shall be entitled to retain privileged information and
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documents embodying Designated Material. If any Designated Material is returned to the parties or
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STIPULATED PROTECTIVE ORDER
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to their counsel by the Clerk of the Court, such material shall also be returned or destroyed as set
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forth above.
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9.
Information or material designated as “Confidential - Attorneys’ Eyes Only,” or
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copies or extracts therefrom and compilations and summaries thereof, may be disclosed,
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summarized, described, characterized, or otherwise communicated or made available in whole or in
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part only to the following persons:
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a)
parties’ outside counsel of record in this action, and regular and temporary
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employees of such counsel to whom it is necessary that the information or material be shown for
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the purposes of this litigation;
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b)
consultants as defined in Paragraph 10 herein and subject to and conditioned
upon compliance with Paragraph 11 herein;
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c)
the Court;
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d)
court reporters and videographers employed in connection with this action;
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e)
graphics or design services retained by counsel for a party for purposes of
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preparing demonstrative or other exhibits for deposition, trial, or other court proceedings in this
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action;
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f)
jury or trial consulting services retained by counsel for a party;
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g)
any other person only upon order of the Court or upon written consent of the
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party producing the confidential information or material subject to and conditioned upon
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compliance with Paragraph 10 herein.
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10.
For purposes of Paragraphs 8(c) and 9(b) herein, a consultant shall be defined as a
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person who is neither an employee of a party nor anticipated to become an employee in the near
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future, and who is retained or employed as a bona fide consultant or expert for purposes of this
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litigation, whether full or part time, by or at the direction of counsel for a party.
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11.
a)
All persons described in Paragraphs 8(b), 8(f), 8(g) and 8(h) may be given
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access to information or material designated as “Confidential”, and all persons described in
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Paragraphs 9(e), 9(f) and 9(g) may be given access to information or material designated as
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STIPULATED PROTECTIVE ORDER
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“Confidential - Attorneys’ Eyes Only,” only on the condition that the individual or corporation first
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confirm their understanding and agreement to abide by the terms of this Protective Order by
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completing and signing a copy of an undertaking in the form attached hereto as Exhibit A. Counsel
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obtaining such an undertaking shall promptly produce a copy to opposing counsel. This paragraph
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shall not apply to persons who are given access to information that has been designated as
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“Confidential” or “Confidential-Attorneys’ Eyes Only” by a party or non-party with whom such
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person is affiliated.
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b)
All persons described in Paragraph 8(c) shall have access to information or
material designated “Confidential”, and the persons described in Paragraph 9(b) shall have access to
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information or material designated “Confidential- Attorneys’ Eyes Only,” only in accordance with
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the following procedure. The attorney proposing to provide access to such information or material
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shall provide to the attorneys of record for the other party the curriculum vitae of such person, and a
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copy of an undertaking in the form attached hereto as Exhibit A signed by such person. Unless the
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attorneys of record for the party receiving the identification of the person proposed to be designated
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pursuant to Paragraphs 8(c) or 9(b) notify the proposing attorneys in writing of an objection to the
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person within seven (7) days after receipt of notification, such designated person shall thereafter be
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deemed qualified to receive information designated “Confidential” (if designated under Paragraph
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8(c)) or “Confidential- Attorneys’ Eyes Only” (if designated under Paragraph 9(b)). Any objection
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to a designated person must be in good faith and reasonably necessary to the protection of a
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legitimate business interest of the objecting party, and the reasons for it shall be stated in writing.
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Following the assertion of an objection, if the parties are unable to resolve their dispute in good
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faith, the party to whom the objection has been made shall so advise the objecting party in writing.
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The objecting party must then seek relief from the Court within a period of ten (10) days from its
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receipt of the letter advising that the parties have been unable to resolve their dispute. If the
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objecting party fails to seek relief from the court within ten (10) days from receipt of the letter, the
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objection shall be deemed withdrawn. In the event of any such objection, there shall be no
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disclosure of “Confidential” or “Confidential- Attorneys’ Eyes Only” information to such person,
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STIPULATED PROTECTIVE ORDER
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except by further order of the Court. This paragraph shall not apply to consultants who are proposed
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to be given access to information that has been designated as “Confidential” or “Confidential-
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Attorneys’ Eyes Only” by the party who has retained that consultant.
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12.
Any witness may be examined at trial or during a deposition or other proceeding
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concerning any Confidential Information which that person had lawfully received or authored prior
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to and apart from this action. During examination, any witness may be shown Confidential
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Information if, from the face of the document or from other documents or testimony, it appears that
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the witness lawfully received or authored such Confidential Information prior to and apart from this
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action, or such Confidential Information was lawfully communicated to that witness prior to and
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apart from this action, provided that prior to the witness testifying as to the Confidential
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Information the examining party makes a reasonable effort to obtain the witness’ compliance with
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paragraph 10.
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A party may challenge the other party’s designation of information or materials
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produced herein as “Confidential” or “Confidential - Attorneys’ Eyes Only” by serving a written
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objection upon the producing party. The producing party shall notify the challenging party in
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writing of the bases for the asserted designation within fifteen (15) days after receiving any written
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objection. The parties shall confer in good faith as to the validity of the designation within fifteen
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(15) days after the challenging party has received the notice of the bases for the asserted
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designation. To the extent the parties are unable to reach an agreement as to the designation, the
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challenging party may make an appropriate application to this Court within fifteen (15) days after
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conferring with the producing party, or if no conferring takes place during the fifteen-day meet and
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confer period (such as a failure by the producing party to respond to the challenging party’s request
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to meet and confer) then, in such case, within fifteen (15) days of the expiration of the fifteen-day
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meet and confer period the application may be made, with confidential portions thereof to be kept
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under seal, requesting that specifically identified documents, information, and/or deposition
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testimony be excluded from the provisions of this Protective Order or downgraded in terms of the
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degree of protection provided. In any such proceeding, the producing party shall bear the burden of
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STIPULATED PROTECTIVE ORDER
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demonstrating that the disputed confidential designations are legally warranted. Failure to make an
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application within the period prescribed in this paragraph shall constitute a waiver of the objection.
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Until a dispute over the asserted designation is finally resolved by the parties or the Court, all
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parties and persons shall treat the information or materials in question as designated as
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“Confidential” or “Confidential- Attorneys’ Eyes Only.” The prevailing party in any motion or
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application to challenge or support such a designation shall be entitled to attorney fees in the
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discretion of the Court provided that the losing party has acted without substantial justification.
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14.
All “Confidential” or “Confidential- Attorneys’ Eyes Only” information and
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material covered by this Protective Order shall be kept in secure facilities, and access to those
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facilities shall be permitted only to those designated persons set forth in Paragraphs 8 and 9 as
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persons properly having access thereto.
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15.
All counsel for the parties who have access to information or material designated as
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“Confidential” or “Confidential- Attorneys’ Eyes Only” under this Protective Order, and all persons
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who execute Exhibit “A” to this Protective Order, acknowledge they are bound by this Order and
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submit to the jurisdiction of this Court for purposes of enforcing this Order.
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16.
Entering into or agreeing to this Protective Order, and/or producing or receiving
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information or material designated as “Confidential” or “Confidential- Attorneys’ Eyes Only,” or
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otherwise complying with the terms of this Protective Order, shall not:
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a)
operate as an admission by any party that any particular information or
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material designated as “Confidential” or” Confidential- Attorneys’ Eyes Only” contains or reflects
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trade secrets, proprietary or commercially sensitive information, or any other type of confidential
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information;
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b)
operate as an admission by any party that the restrictions and procedures set
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forth herein constitute or do not constitute adequate protection for any particular information
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deemed by any party to be “Confidential” or “Confidential- Attorneys’ Eyes Only;”
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c)
prejudice in any way the rights of the parties to object to the production of
documents they consider not subject to discovery;
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STIPULATED PROTECTIVE ORDER
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d)
prejudice in any way the rights of any party to object to the authenticity or
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admissibility into evidence of any document, testimony or other evidence subject to this Protective
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Order;
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e)
Court whether any information or material should be subject to the terms of this Protective Order;
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f)
prejudice in any way the rights of a party to petition the Court for a further
protective order relating to any purportedly confidential information;
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prejudice in any way the rights of a party to seek a determination by the
g)
prejudice in any way the rights of a party to make a separate application to
the Court that information or materials of proprietary or competitive value, but which is not
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specifically included in the categories of “Confidential- Attorneys’ Eyes Only” information or
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materials itemized in Paragraph 3 above, should be properly designated “Confidential- Attorneys’
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Eyes Only;”
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h)
prevent the parties to this Protective Order from agreeing in writing or on the
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record during a deposition or hearing in this action to alter or waive the provisions or protections
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provided for herein with respect to any particular information or material;
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i)
limit a party’s ability to grant non-parties access to its own documents and/or
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information. An individual or corporate party to the above-captioned action, and any third party
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deponent who is not an expert witness or consultant, may only have access to the information or
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material produced by that individual or corporation, and shall not be given access to any other
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confidential information or material designated as “Confidential Attorneys’ Eyes Only” produced
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by another individual or corporation.
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This Protective Order has no effect upon, and shall not apply to, a party’s use or
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disclosure of its own confidential information for any purpose. Nothing contained herein shall
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impose any restrictions on the use or disclosure by a party of documents, information, or material
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designated as “Confidential” or “Confidential- Attorneys’ Eyes Only’ obtained lawfully by such
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party independently of any proceedings in this action, or which:
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STIPULATED PROTECTIVE ORDER
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a)
was already known to such party by lawful means prior to acquisition from,
or disclosure by, the other party in this action;
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b)
is or becomes publicly known through no fault or act of such party; or
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c)
is rightfully received by such party from a third party which has authority to
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provide such information or material and without restriction as to disclosure.
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d)
Notwithstanding this provision, no party to this action (without agreement of
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the parties or Order of the Court) shall be permitted access to any information or documents
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designated “Confidential” or “Confidential-Attorney’s Eyes Only” based on its claim that the
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opposing party’s designated information or documents were “stolen” or “misappropriated” or
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rightfully belong to that party wishing such access.
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In the event that information in the possession or control of a party involves the
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confidentiality rights of a non-party or its disclosure would violate a Protective Order issued in
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another action, the party with possession or control of the information will attempt to obtain the
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consent of the non-party to disclose the information under this Order, If the consent of the non-
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party cannot be obtained, the party will notify the party seeking discovery of (a) the existence of the
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information without producing such information; and (b) the identity of the non-party (provided,
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however, that such disclosure of the identity of the non-party does not violate any confidentiality
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obligations). The party seeking discovery may then make further application to the non-party or
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seek other means to obtain such information.
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19.
If a party inadvertently produces “Confidential,” or “Confidential- Attorneys’ Eyes
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Only” information without marking it as such, it may be disclosed to others until the receiving party
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becomes aware of the error, unless it appears froth the face of the document that it contains non-
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public, confidential, proprietary, commercially sensitive, or trade secret information of the
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producing party. As soon as the receiving party becomes aware of the inadvertent production, the
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information must be treated as if it had been timely designated under this Protective Order, and the
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receiving party must endeavor in good- faith to obtain all copies of the document which it
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STIPULATED PROTECTIVE ORDER
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distributed or disclosed to persons not authorized to access such information by Paragraphs 8 or 9
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above, as well as any copies made by such persons.
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20.
The terms of this Protective Order shall apply to all manner and means of discovery,
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including entry onto land or premises, and inspection of books, records, documents, and tangible
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things.
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21.
It is the present intention of the parties that the provisions of this Protective Order
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shall govern discovery and other pretrial and trial proceedings in this action. Nonetheless, each of
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the parties hereto shall be entitled to seek modification of this Protective Order by application to the
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Court on notice to the other party hereto for good cause. The prevailing party in any motion to
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modify this Order shall be entitled to attorney fees in the discretion of the Court provided that the
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losing party has acted without substantial justification.
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22.
The parties agree to be bound by the terms of this Protective Order pending its entry
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by the Court, or pending the entry of an alternative thereto which is satisfactory to all parties, and
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any violation of its terms shall be subject to the same sanctions and penalties as if the Protective
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Order had been entered by the Court.
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23.
The provisions of this Protective Order shall, absent written permission of the
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producing party or further order of the Court, continue to be binding throughout and after the
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conclusion of this action, including without limitation any appeals therefrom. Within sixty (60)
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days after receiving notice of the entry of an order, judgment, or decree finally disposing of this
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action, including any appeals therefrom, all persons having received information or material
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designated as “Confidential” or “Confidential- Attorneys’ Eyes Only” hereunder shall return such
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material and all copies thereof (including summaries and excerpts) to counsel for the producing
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party, or shall certify destruction thereof. Counsel described in paragraphs 8(a) and 9(a), above,
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shall be entitled to retain court papers, deposition and trial transcripts, and attorney work product
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(including court papers, transcripts, and attorney work product that contain information or material
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designated as “Confidential” or “Confidential- Attorneys’ Eyes Only”) provided that such counsel,
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and employees of such counsel, shall not disclose any such information and material designated as
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STIPULATED PROTECTIVE ORDER
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“Confidential” or “Confidential- Attorneys’ Eyes Only” contained in such court papers, transcripts,
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or attorney work product to any person or entity except pursuant to court order or a written
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agreement with the producing party of the information or material. All materials returned to the
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parties or counsel by the Court likewise shall be disposed of in accordance with this paragraph.
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24.
In the event that any information or material designated as “Confidential” or
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“Confidential- Attorneys’ Eyes Only” hereunder is used in any court proceeding in this action or
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any appeal therefrom, such information or material shall not lose its status as “Confidential” or
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“Confidential- Attorneys Eyes Only” through such use. Counsel for the parties shall confer on such
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procedures as are necessary to protect the confidentiality of any documents, information and
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transcripts used in the course of any court proceedings, and shall incorporate such procedures, as
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appropriate, in the pre-trial order.
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25.
If any party:
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a)
is subpoenaed in another action,
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b)
is served with a demand in another action to which it is a party, or
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c)
is served with any other legal process by one not a party to this action,
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seeking information or material which was produced or designated as “Confidential” or
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“Confidential- Attorneys’ Eyes Only” by someone other than that party, the party shall give prompt
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written notice, by hand or facsimile transmission, within five (5) days of receipt of such subpoena,
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demand or legal process, to those who produced or designated the information or material marked
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as “Confidential” or “Confidential- Attorneys’ Eyes Only” and shall object to its production to the
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extent permitted by law. Should the person seeking access to the information or material take action
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against the party or anyone else covered by this Protective Order to enforce such a subpoena,
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demand, or other legal process, the party shall respond by setting forth the existence of this
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Protective Order. Nothing herein shall be construed as requiring the party or anyone else covered
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by this Protective Order to challenge or appeal any order requiring production of information or
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material covered by this Protective order, or to subject itself to any penalties for noncompliance
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with any legal process or order, or to seek any relief from this Court.
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STIPULATED PROTECTIVE ORDER
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26.
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No party may pursuant to this order designate as confidential information or
materials:
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a)
which constitute public records; and
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b)
which was obtained from third parties who owed no duty of confidentiality to
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the receiving or producing parties.
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IT IS SO STIPULATED.
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DATED: December 14, 2011
WANG, HARTMANN, GIBBS & CAULEY
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By: /s/ John D. van Loben Sels
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John D. van Loben Sels
Kenneth A. Ohashi
Attorneys for Sixxon Precision Machinery Co., Ltd.
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DATED: December 14, 2011
LAW OFFICES OF MICHAEL G. ACKERMAN
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By: /s/ Michael G. Ackerman
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Michael G. Ackerman
Attorney for Mechanical Marketing, Inc.,
Arnold Dolgins, and Carol Dolgins
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PURSUANT TO STIPULATION, IT IS SO ORDERED.
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DATED: 12/20/2011
MAGISTRATE JUDGE
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STIPULATED PROTECTIVE ORDER
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EXHIBIT A
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CONFIDENTIALITY AGREEMENT
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The undersigned hereby acknowledges that he or she has read and is familiar with
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the attached Stipulated Protective Order entered in the action Mechanical Marketing, Inc. v. Sixxon
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Precision Machinery, Co., Ltd., currently pending in the United States District Court for Northern
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District of California, and understands the terms thereof and agrees to be bound by such terms.
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DATED: ____________
____________________________________
Signature
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__________________________________________
(Type or Print Name of Individual)
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STIPULATED PROTECTIVE ORDER
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IT IS SO STIPULATED.
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DATED: December 14, 2011
WANG, HARTMANN, GIBBS & CAULEY
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By: /s/ John D. van Loben Sels
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John D. van Loben Sels
Kenneth A. Ohashi
Attorneys for Sixxon Precision Machinery Co., Ltd.
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DATED: December 14, 2011
LAW OFFICES OF MICHAEL G. ACKERMAN
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By: /s/ Michael G. Ackerman
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Michael G. Ackerman
Attorney for Mechanical Marketing, Inc.,
Arnold Dolgins, and Carol Dolgins
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PURSUANT TO STIPULATION, IT IS SO ORDERED.
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DATED:
MAGISTRATE JUDGE
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STIPULATION AND [PROPOSED] ORDER FOR PROTECTIVE ORDER
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CERTIFICATE OF SERVICE
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Pursuant to Civil L.R. 5-6, the undersigned hereby certifies that all counsel of record who
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are deemed to have consented to electronic service are being served with a copy of this document
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via the Court’s CM/ECF system on December 15, 2011.
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/s/ John D. van Loben Sels
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John D. van Loben Sels
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STIPULATION AND [PROPOSED] ORDER FOR PROTECTIVE ORDER
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