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Blackstar v. County of Orange

May 4, 2009

JOANN BLACKSTAR, ET AL., PLAINTIFFS,
v.
COUNTY OF ORANGE, ET AL., DEFENDANTS.



The opinion of the court was delivered by: Honorable Marc L. Goldman, United States Magistrate Judge

[PROPOSED] PROTECTIVE ORDER RELATING TO DISCOVERY OF CONFIDENTIAL INFORMATION

NOTE: CHANGES HAVE BEEN MADE TO THIS DOCUMENT GOOD CAUSE APPEARING THEREFORE AND IN ACCORDANCE WITH THE STIPULATION OF THE PARTIES, IT IS HEREBY ORDERED THAT:

1. In connection with discovery in this action the parties may designate any document, thing, material, testimony or other information derived therefrom, as "Confidential" under the terms of this Stipulated Protective Order (hereinafter "Order").

For purposes of this Order Confidential information is information which is protected from disclosure under statutory and/or regulatory authorities as delineated in the Stipulation of the Parties.

2. This Order is establishing a standard of confidentiality for the parties that is similar to the confidentiality that binds the Orange County Social Services Agency ("SSA") as the administrator of the public assistance programs at issue in this litigation.

3. Confidential materials shall, however, not include any documents concerning information that at any time has been: (i) produced, disclosed or made available to the public or otherwise available for public access; (ii) disclosed in connection with any governmental public filing and which documents or information could not reasonably be assumed to be or have been intended to be kept confidential; (iii) published, communicated or disseminated to others who are not obligated, whether by this Order or otherwise, to maintain the confidentiality of information contained therein; or (iv) any document that has not been preserved or maintained in a manner calculated to preserve its confidentiality. The occurrence of any of the conditions listed in (i) through (iv) of this paragraph serves as a waiver of the previous designation of material as "confidential." If, however, a condition listed in (i) through (iv) of this paragraph occurs through the inadvertence of the party seeking to keep the information confidential, such occurrence will not serve as a waiver if the party takes prompt action to reverse the inadvertent disclosure. Should the non-designating party take any action that compromises confidentiality, whether inadvertent or otherwise, the non-designating party will make reasonable efforts to reverse that condition.

4. By designating a document, thing, material, testimony or other information derived therefrom as "confidential," under the terms of this Order, the party making the designation is certifying to the Court that there is a good faith basis both in law and in fact for the designation within the meaning of Federal Rule of Civil Procedure 26(g).

5. Confidential documents shall be so designated by stamping copies of the document produced to a party with the legend "CONFIDENTIAL." Stamping the legend "CONFIDENTIAL" on the cover of any multipage document shall designate all pages of the document as confidential, unless otherwise indicated by the producing party.

6. Testimony taken at a deposition, conference, hearing or trial may be designated as confidential by making a statement to that effect on the record at the deposition or other proceeding. Arrangements shall be made with the court reporter taking and transcribing such proceeding to separately bind such portions of the transcript containing information designated as confidential, and to label such portions appropriately.

7. Material designated as confidential under this Order, the information contained therein, and any summaries, copies, abstracts, or other documents derived in whole or in part from material designated as confidential (hereinafter "Confidential Material") shall be used only for the purpose of the prosecution, defense, or settlement of this action, and for no other purpose.

8. Confidential Material produced pursuant to this Order may be disclosed or made available only to the Court, to counsel for a party (including the paralegal, clerical, and secretarial staff employed by such counsel), and to the "qualified persons" designated below:

a. a party, or an officer, director, or employee of a party deemed necessary by counsel to aid in the prosecution, defense, or settlement of this action;

b. experts or consultant (together with their clerical staff) retained by such counsel to assist in the prosecution, ...


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