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Gargale v. Fortinet

April 1, 2009


The opinion of the court was delivered by: The Honorable Patricia V. Trumbull United States Magistrate Judge


confidential, proprietary, or private information for which special protection from public disclosure and from use for any purpose other than this litigation would be warranted.

Stipulated Protective Order

The parties acknowledge that this Order does not confer blanket protections on all disclosures or responses to discovery and that the protection it affords extends only to the limited information or items that are entitled to treatment as confidential under the applicable legal principles. The parties further acknowledge, as set forth in Section 10, below, that this Stipulated Protective Order creates no entitlement to file confidential information under seal; Civil Local Rule 79-5 sets forth the procedures that must be followed and reflects the standards that will be applied when a party seeks permission from the court to file material under seal.

2.1 Party: any party to this action, including all of its officers, directors, employees, consultants, retained experts, and outside counsel (and their support staffs).

the medium or manner generated, stored, or maintained (including, among other things, testimony, transcripts, or tangible things) that are produced or generated in disclosures or responses to discovery in this matter.

generated, stored or maintained) or tangible things that qualify for protection under standards developed under Federal Rule of Civil Procedure 26(c).

from a Producing Party.

Discovery Material in this action.


Disclosure and discovery activity in this action are likely to involve production of Accordingly, the parties hereby stipulate to and petition the Court to enter the following


2.2 Disclosure or Discovery Material: all items or information, regardless of

2. Confidential Information or Items: information (regardless of how

2. Receiving Party: a Party that receives Disclosure or Discovery Material

2. Producing Party: a Party or non-party that produces Disclosure or

items that it produces in disclosures or in responses to discovery as "Confidential."

designated as "Confidential."

retained to represent or advise a Party in this action (as well as their support staffs).

support staffs).

as their support staffs).

pertinent to the litigation who has been retained by a Party or its counsel to serve as an expert witness or as a consultant in this action and who is not a past or a current employee of a Party or of a competitor of a Party and who, at the time of retention, is not anticipated to become an employee of a Party or a competitor of a Party. This definition includes a professional jury or trial consultant retained in connection with this litigation.

services (e.g., photocopying; videotaping; translating; preparing exhibits or demonstrations; organizing, storing, retrieving data in any form or medium; etc.) and their employees and subcontractors.

The protections conferred by this Stipulation and Order cover not only Protected Material (as defined above), but also any information copied or extracted therefrom, as well as all copies, excerpts, summaries, or compilations thereof, plus testimony, conversations, or presentations by parties or counsel to or in court or in other settings that might reveal Protected Material.

Even after the termination of this litigation, the confidentiality obligations imposed by this Order shall remain in effect until a Designating Party agrees otherwise in writing or a court

2.6 Designating Party: a Party or non-party that designates information or

2.7 Protected Material: any Disclosure or Discovery Material that is

2.8 Outside Counsel: attorneys who are not employees of a Party but who are

2.9 House Counsel: attorneys who are employees of a Party (as well as their

2.10 Counsel (without qualifier): Outside Counsel and House Counsel (as well

2.11 Expert: a person with specialized knowledge or experience in a matter

2.12 Professional Vendors: persons or entities that provide litigation support



order otherwise directs.

this Order must take care to limit any such designation to specific material that qualifies under the appropriate standards. A Designating Party must take care to designate for protection only those parts of material, documents, items, or oral or written communications that qualify -- so that other portions of the material, documents, items, or communications for ...

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