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Herrera v. Hitman Fight Gear

March 20, 2009

PAUL HERRERA, AN INDIVIDUAL, PLAINTIFF,
v.
HITMAN FIGHT GEAR, LLC, A CALIFORNIA LIMITED LIABILITY COMPANY; DANIEL DIAZ, AN INDIVIDUAL; GRAPHIC INK, CORP., A CALIFORNIA CORPORATION; VINNIE DE LA TORRE, AN INDIVIDUAL; FIGHT INDUSTRIES, LLC, A CALIFORNIA LIMITED LIABILITY COMPANY; DAN CALDWELL, AN INDIVIDUAL; TAPOUT LLC, A CALIFORNIA LIMITED LIABILITY COMPANY; CHARLES LEWIS, AN INDIVIDUAL;; AND DOES 3-10, INCLUSIVE, DEFENDANTS.



The opinion of the court was delivered by: Hon. Victor B. Kenton United States Magistrate Judge

NOTE: CHANGES HAVE BEEN MADE TO THIS DOCUMENT

ORDER GRANTING STIPULATED PROTECTIVE ORDER

Hearing Date: None

Judge: Hon. Andrew J. Guilford Courtroom: 10-D Santa Ana Court House 411 West 4th Street Santa Ana, California 92701

The Court, having considered the Stipulated Protective Order executed by the parties on or about March 6, 2009, hereby ORDERS as follows:

I. APPLICABILITY

Confidential Information produced in this litigation shall be used solely for the purposes of this lawsuit and for no other purpose. The restrictions herein on the use and disclosure of Confidential Information shall apply to any documents or materials that incorporate, summarize, refer to, or contain Confidential Information produced, exchanged or disclosed in connection with this lawsuit. Nothing in this Protective Order prevents a party from moving for an additional protective order.

II. CATEGORIES AND LIMITATIONS

A. "CONFIDENTIAL" DESIGNATION

1. Any party may designate as "CONFIDENTIAL INFORMATION" any document, deposition testimony, discovery response or other material that the party considers in good faith to be non-public confidential or proprietary information entitled to protection from disclosure to the general public or subject to a legally protected right of privacy or other such right.

A producing party shall designate any document containing Confidential Information by stamping on each page thereof containing Confidential Information the word "CONFIDENTIAL." In lieu of stamping the original documents, the producing party may stamp the copies that are produced or exchanged. In lieu of same, the producing party may advise the receiving party at time of production which documents are deemed CONFIDENTIAL by a writing describing said documents at the time of production, or within 5 days after the date thereof. The producing party shall designate other materials containing Confidential Information by stamping or marking them in a similar manner to the extent practicable. When Confidential Information is produced in a form not appropriate for such stamping or marking, it shall be designated in writing as Confidential Information at the time it is produced. A party may designate as "CONFIDENTIAL" any documents or materials containing Confidential Information produced by a non-party by providing written notice to all parties and the producing non-party of such designation. After any such designation, such documents and materials shall be fully subject to this Protective Order and treated thereafter according to the new designation.

Any non-party witness or other person, firm or entity from which discovery is sought in this lawsuit may also designate as "CONFIDENTIAL" any documents or material containing Confidential Information produced or testified to by such non-party by designating such documents or material as "CONFIDENTIAL." After such designation, such documents and materials shall be fully subject to this Protective Order and treated thereafter according to the designation.

2. Confidential Information shall not be disclosed to any person or entity other than:

(a) Counsel of record and employees of counsel of record (such as paralegals, clerks, and secretaries) actively engaged in this litigation, and their contractors, including outside copy services and litigation support teams;

(b) Officers, in-house counsel, or other employees of the receiving party who are actively engaged in assisting in the prosecution or defense of this litigation;

(c) Independent consultants and expert witnesses (and the professional secretarial and clerical staff of consultants and experts) who are retained by any party or its trial or in-house counsel to furnish services in connection with this action, subject to the requirements of paragraph (A)(3) below; but only after advance disclosure of the names of their experts and consultants has been provided to the other party before allowing disclosure of confidential information to avoid any potential conflicts of interest.

(d) Trial and appellate courts for this action, and court reporters and necessary support personnel of such court reporters retained in connection with depositions taken by any party in this litigation to the extent necessary to transcribe the deposition ...


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