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SPRINT TELEPHONY PCS, L.P. v. COUNTY OF SAN DIEGO

May 31, 2004.

SPRINT TELEPHONY PCS, L.P., a Delaware limited partnership, and PACIFIC BELL WIRELESS, LLC, a Nevada limited liability company, dba CINGULAR WIRELESS, Plaintiffs
v.
a division of the state of California; GREG COX, in his capacity as a supervisor of the County of San Diego; DIANNE JACOB, in her capacity as a supervisor of the County of San Diego; PAM SLATER, in her capacity as a supervisor of the County of San Diego; RON ROBERTS, in his capacity as a supervisor of the County of San Diego; and BILL HORN, in his capacity as a supervisor of the County of San Diego, Defendants



The opinion of the court was delivered by: JUDITH KEEP, District Judge

PROTECTIVE ORDER

This Protective Order Regarding Confidential Information ("Protective Order") between SPRINT TELEPHONY PCS, L.P. ("Sprint") and PACIFIC BELL WIRELESS, LLC dba CINGULAR WIRELESS ("Cingular") (collectively "Plaintiffs") and COUNTY OF SAN DIEGO ("County"), GREG COX, in his capacity as a supervisor of the County of San Diego; DIANNE JACOB, in her capacity as a supervisor of the County of San Diego; PAM SLATER, in her capacity as a supervisor of the County of San Diego; RON ROBERTS, in his capacity as a supervisor of the County of San Diego; and BILL HORN, in his capacity as a supervisor of the County of San Diego ("collectively "Defendants") by and through their counsel of record, is made in the above-captioned action with respect to the following recitals:

WHEREAS, the Plaintiffs to this action expect that they will be requested to produce documents, provide testimony and/or otherwise disclose sensitive and confidential financial and business information and other information that requires protection as sensitive, confidential, proprietary or trade secret information, and/or by the right to privacy; and

  WHEREAS, the parties to this action seek to establish procedures that will protect all confidential information while expediting the discovery process, limiting the necessity for objections or subsequent motions seeking to limit discovery and facilitating the disposition by the Court of any disputes that may arise in connection with discovery.

  NOW, THEREFORE, subject to the approval of the Court, it is hereby stipulated and agreed, by and between the parties, through their respective counsel, as follows:
1. DEFINITIONS
The following definitions shall apply to this Protective Order:
  a. The "Action" shall mean and refer to the above-captioned matter and to all actions now or later consolidated with the Action, and any appeal from the Action, and from any other action consolidated at any time under the above-captioned matter, through final judgment.

  b. "Confidential Document" shall mean any document that any Designating Party (as defined below) designates as "Confidential" or "Confidential — Attorneys' Eyes Only" in the manner set forth in this Protective Order; provided, however, that by agreeing to this Protective Order, no party waives the right to challenge any other party's designation of any document as "Confidential" or "Confidential — Attorneys' Eyes Only."

  c. "Confidential Information" shall mean any information not made available to the general public that concerns or relates to trade secret, business, financial, and/or personal information.

  d. "Designating Party" shall mean any party in this Action designating information or a document as "Confidential" or "Confidential — Attorneys' Eyes Only."

  e. "Receiving Party" shall mean any party in this Action receiving Confidential Documents or Confidential Information of a Designating Party. A Receiving Party may be a co-Plaintiff with the Designating Party.

  f. "Legend" as used herein shall mean a stamp or similar insignia stating "Confidential" or "Confidential — Attorneys' Eyes Only," or other appropriate term or terms identifying the level of confidentiality of the document.

  g. When reference is made in this Protective Order to any document, the singular shall include the plural, and plural shall include the singular.

  2. DESIGNATION OF DOCUMENTS

  a. The Designating Party may designate a document as "Confidential" or "Confidential — Attorneys' Eyes Only" by affixing the appropriate Legend to all copies of the document at the time of production. Except as provided herein, the Designating Party must make document designations at the time of production or within fourteen (14) days of the entry of this Protective Order, whichever is later.

  b. A party may designate as "Confidential" or "Confidential — Attorneys' Eyes Only" a document produced by someone else by informing in writing all parties the control number of such document within seven (7) days of that party's receipt of the document or within seven (7) days of the entry of this Protective Order, whichever is later.

  c. All parties receiving written notice of such designation shall affix the appropriate Legend to all pages of any copy or copies of such document in their possession. d. Any party may designate a deposition or hearing transcript (or any portion thereof or exhibit thereto) as "Confidential" or "Confidential — Attorneys' Eyes Only" by: (i) making such designation on the record during the deposition or hearing (in which case the stenographer shall affix the appropriate Legend to the cover page and all designated pages of the transcript and all copies thereof); or (ii) informing counsel for all other parties of such designation in writing within seven (7) days after receipt of the ...


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