Hohenberg v. Ferrero USA, Inc

Filing 29

Joint MOTION for Protective Order Joint Motion Requesting Entry of Protective Order by Ferrero USA, Inc. (Bish, Dale) (ag).

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KEITH E. EGGLETON, State Bar No. 159842
COLLEEN BAL, State Bar No. 167637
DALE R. BISH, State Bar No. 235390
AMIR STEINHART, State Bar No. 275037
WILSON SONSINI GOODRICH & ROSATI
Professional Corporation
650 Page Mill Road
Palo Alto, CA 94304-1050
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Defendant
FERRERO U.S.A, INC.

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UNITED STATES DISTRICT COURT
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FOR THE SOUTHERN DISTRICT OF CALIFORNIA
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In re FERRERO LITIGATION
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CASE NO.: 11 CV 0205 (H CAB)

JOINT MOTION REQUESTING
ENTRY OF PROTECTIVE ORDER

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JOINT MOTION REQUESTING ENTRY OF
PROTECTIVE ORDER

11CV0205

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WHEREAS Plaintiffs Athena Hohenberg and Laura Rude-Barbato and Defendant Ferrero

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U.S.A., Inc. (the “parties”) have stipulated to the terms of a proposed protective order to govern

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the production of confidential and proprietary information in this action;

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WHEREAS, a copy of the stipulated proposed protective order, in the form agreed upon by

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the parties, is being submitted to the Court via electronic mail, consistent with the local rules of

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the Court;

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THEREFORE, the parties, by and through their undersigned counsel, jointly request and

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hereby move for the entry of a Protective Order regarding confidential information in this matter

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in the form set forth in the proposed protective order submitted to the Court, or as otherwise

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deemed appropriate by the Court.

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Dated: April 15, 2011

WILSON SONSINI GOODRICH & ROSATI
Professional Corporation

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By: s/ Dale R. Bish
Dale R. Bish

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650 Page Mill Road
Palo Alto, CA 94304-1040
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Defendant
FERRERO U.S.A., INC.

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Dated: April 15, 2011

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THE WESTON FIRM

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By: s/ Gregory S. Weston
Gregory S. Weston

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Attorneys for Plaintiffs Athena Hohenberg and
Laura Rude-Barbato.

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JOINT MOTION REQUESTING ENTRY OF
PROTECTIVE ORDER

11CV0205

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I, Dale R. Bish, am the ECF User whose identification and password are being used to file this

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Stipulation. I hereby attest that Gregory S. Weston has concurred in this filing.

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Dated: April 15, 2011

WILSON SONSINI GOODRICH & ROSATI
Professional Corporation

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By: s/ Dale R. Bish
Dale R. Bish
Attorneys for Defendant Ferrero U.S.A., Inc.
E-mail: [e-mail]

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JOINT MOTION REQUESTING ENTRY OF
PROTECTIVE ORDER

11CV0205

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CERTIFICATE OF SERVICE

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I am employed in the County of Santa Clara, State of California. I am over the age of

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eighteen years and not a party to the within action; my business address is 650 Page Mill Road,

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Palo Alto, California 94104-1050.

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On April 15, 2011, I served the following document on the interested parties in this

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action: JOINT MOTION REQUESTING ENTRY OF PROTECTIVE ORDER by causing

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the above document to be served via the Court’s Electronic Filing System on the following

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registered parties shown on the court’s service list by posting such document electronically to the

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ECF website of the united States District Court for the Southern District of California:

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Ronald A. Marron, Esq.
[e-mail]
Law Offices of Ronald A. Marron, APLC
3634 4th Avenue, Suite 202
San Diego, CA 92103

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Gregory S. Weston
Jack Fitzgerald
[e-mail]
[e-mail]
The Weston Firm
888 Turquoise Street
San Diego, CA 92109

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I declare under penalty of perjury under the laws of the United States of America that the

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foregoing is true and correct.

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Dated: April 15, 2011

WILSON SONSINI GOODRICH & ROSATI
Professional Corporation

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By: s/ Dale R. Bish
Dale R. Bish
Attorneys for Defendant Ferrero U.S.A., Inc.
E-mail: [e-mail]

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JOINT MOTION REQUESTING ENTRY OF
PROTECTIVE ORDER

11CV0205

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