The opinion of the court was delivered by: Hon. Paul L. Abrams United States Magistrate Judge
1. PURPOSES AND LIMITATIONS
STIPULATED PROTECTIVE ORDER
[Stipulated Protective Order is not limited to discovery and is for consideration by the district judge]
Disclosure and discovery activity in this action are likely to involve production of confidential, proprietary, or private information for which special protection from public disclosure and from use for any purpose other than prosecuting this litigation would be warranted. Accordingly, the Parties hereby stipulate to and petition theCourt to enter the following Stipulated Protective Order ("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 under the applicable legal principles to treatment as confidential. The Parties further acknowledge that, to the extent that submissions containing Protected Material (as defined below) need to be filed with the Court, the Parties shall follow the relevant procedures contained in the Federal Rules of Civil Procedure and the local rules of this Court.
2.1. Party: any party to the above-captioned action currently pending in the Central District of California.
2.2. Disclosure or Discovery Material: all items or information, regardless of the medium or manner generated, stored, or maintained (including, among other things, deposition or court testimony or transcripts, affidavits or declarations, or tangible things) that are produced or generated in disclosures or responses to discovery in this matter.
2.3. Confidential Information or Confidential Items: For the purposes of this Order, "Confidential Information or Confidential Items" means:
(a) Information that constitutes a trade secret in accordance with Cal. Civil Code § 3426.1;
(b) Non-public communications with regulators or other governmental bodies that are protected from disclosure by statute or regulation;
(c) Private Consumer Information as defined below in paragraph 2.4; and
(d) Non-public business or financial strategies, business plans, strategic plans, marketing plans, marketing surveys, and contracts or agreements.
2.4. Private Consumer Information: Private consumer information that contains identifying, contact or private financial information provided by a consumer to a financial institution, resulting from any transaction with the consumer or any service performed for the consumer, or otherwise obtained by the financial institution, including any list, description, or other grouping of consumers (and publicly available information pertaining to them) that is derived using any nonpublic personal information, including any "nonpublic personal information" such as identified by the Gramm-Leach-Bliley Act, 15 U.S.C. § 6801 et seq.
2.5. Producing Party: a Party or non-party that produces Disclosure or Discovery Material in this action.
2.6. Receiving Party: a Party that receives Disclosure or Discovery Material from a Producing Party.
2.7. Designating Party: a Party or non-party that designates information or items that it produces in disclosures or in responses to discovery as "Confidential."
2.8. Protected Material: any Disclosure or Discovery Material that is designated as "Confidential."
2.9. Outside Counsel: attorneys who are not employees of a Party but who are retained to represent or advise a Party in this action, including the attorneys' support staff.
2.10. In-House Counsel: attorneys who are employees of a Party, including the attorneys' support staff.
2.11. Counsel (without qualifier): Outside Counsel and In-House Counsel.
The protections conferred by this Order cover not only Protected Material (as defined above), but also (i) any information reproduced, copied or extracted therefrom, (ii) all copies, excerpts, summaries, or compilations thereof, and (iii) testimony, conversations, or presentations by Parties or Counsel to or in court or in other settings that might reveal Protected Material or Confidential Information or Confidential Items. This Order shall be fully applicable to material produced by or testimony taken of third parties or non-parties, and any third party from whom discovery is sought shall be entitled to designate material and testimony as Confidential Information or Confidential Items pursuant to the terms of this Order.
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 ...