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International Lease Finance Corp. v. Air Comet

June 15, 2009

INTERNATIONAL LEASE FINANCE CORPORATION, A CALIFORNIA CORPORATION, AND CASTLE 2003-1C LLC, A DELAWARE LIMITED LIABILITY COMPANY; PLAINTIFFS,
v.
AIR COMET, S.A., A SPANISH CORPORATION; AND INTERINVEST, S.A., AN ARGENTINE CORPORATION. DEFENDANTS.



The opinion of the court was delivered by: Hon. John F. Walter

STIPULATION AND PROTECTIVE ORDER

Trial Date: January 26, 2010

Action Filed: December 2, 2008

Pursuant to Fed. R. of Civ. Proc. 26(c), plaintiffs International Lease Finance Corporation and Castle 2003-1C LLC and defendants Air Comet, S.A. and Interinvest, S.A. stipulate that the following Protective Order may be entered by this Court:

1. Introduction and Scope

This Protective Order shall govern any designated record of information produced in this Action, including all designated motions and other papers submitted to the Court in this Action, all designated deposition testimony, all designated testimony taken at a hearing or other proceeding, interrogatory answers, Documents and other discovery materials, whether produced informally or in response to interrogatories, requests for admissions, requests for production of documents or other formal method of discovery or as part of any disclosure required by Rule 26 of the Federal Rules of Civil Procedure or local rule.

2. Definitions

a) "Action": refers to the above-captioned matter, International Lease Finance Corp., et al. v. Air Comet, S.A., et al., Case No. CV 08-7928 JFW (JCx), now pending in the United States District Court for the Central District of California.

b) "Confidential Information": means any non-public, commercially valuable information of a Producing Party that meets the criteria stated in the Introduction of this Protective Order.

c) "Counsel" (without qualifier): includes Outside Counsel and House Counsel, as well as their support staffs, as defined herein.

d) "Documents": means all information, documents or things within the scope of Fed. R. Civ. P. Rule 34.

e) "House Counsel": means attorneys who are employees of a Party to this Action.

f) "Outside Counsel": means attorneys who are not employees of a Party but who are retained to represent or advise a Party in this Action.

g) "Party": refers to any party to the Action, including all of its officers, directors, and employees, and its Outside Counsel retained by that party for this Action, including such counsel's support staff.

h) "Producing Party": refers to a Party or third party that designates Documents or testimony as CONFIDENTIAL pursuant to this Protective Order.

i) "Protected Material": refers to any Document or testimony that is designated as CONFIDENTIAL pursuant to this Protective Order.

j) "Receiving Party": a Party that receives Documents in the Action.

k) "Termination of this Action": refers to the earlier of: (a) when there is a settlement with prejudice in this Action with respect to all causes of action; (b) when there is a final judgment ending this Action that is no longer subject to appeal; and (c) when there is an appellate opinion ending this Action that is no longer subject to further appeal or petition for review.

3. Designation of Documents

Each Producing Party shall have the right to designate as confidential and subject to this Protective Order any information, Document or portion of any Document produced by it or a third party in this litigation, which the Producing Party believes in good faith contains its trade secrets or other confidential technical, business or financial information that the party would not normally reveal to third parties, or would require third parties to maintain in confidence. This designation shall be made by stamping each page of the Document or electronically stored information containing Confidential Information with the legend "CONFIDENTIAL -- Subject To Protective Order" prior to its production or, if inadvertently produced without such legend, by promptly furnishing written notice to the Receiving Party that the information or Document shall be CONFIDENTIAL under this Protective Order along with appropriately labeled copies of the Documents in question. To the extent that the Receiving Party has already disclosed such information or Document, the Receiving Party shall promptly collect any copies of Protected Material that have been provided to individuals other than those authorized under this Protective Order, and shall destroy or return them to the Producing Party.

With respect to all materials provided for inspection by a Producing Party's counsel, designation by stamping or labeling as CONFIDENTIAL need not be made until copies of the materials are requested after inspection and selection by counsel. Making Documents and things available for inspection shall not constitute a waiver of any claim of confidentiality, and all materials provided for inspection by a Producing Party's counsel shall be treated as though designated as CONFIDENTIAL at the time of the inspection.

4. Limit on Use of Designated Information

Each Party and all persons bound by the terms of this Protective Order shall use any information or Document governed by this Protective Order only for the purpose of prosecution or defense of this Action; no Party or other person shall use any information or Document governed by this Protective Order for any purpose other than the prosecution or defense of this Action. It is, however, understood that Counsel for a Party may give advice and opinions to his or her client based on his or her evaluation of information designated as CONFIDENTIAL produced by the opposing Party provided that such rendering of advice and opinions shall not reveal the content of such information except by prior agreement with Counsel for the Producing Party. The attorneys of record for the Parties shall exercise reasonable care to ensure that the information and Documents governed by this Protective Order are (a) used only for the purposes specified herein, and (b) disclosed only to authorized persons.

5. CONFIDENTIAL Material

Except as otherwise provided by written stipulation of the Producing Parties or by further order of the Court, Documents or information designated as CONFIDENTIAL shall only be disclosed on a need-to-know basis. No Documents or information designated as CONFIDENTIAL shall be disclosed by the Receiving Party to any third party except by written stipulation of the Producing Parties or by order of the Court. The Parties shall store and maintain information and Documents designated as CONFIDENTIAL in a secure manner to ensure that access is limited to the individuals authorized under this Protective Order.

6. Persons With Access to CONFIDENTIAL Materials

Unless otherwise ordered by the Court or permitted in writing by the Producing Party, a Receiving Party may disclose any Protected Material designated as CONFIDENTIAL only to:

a) the Receiving Party's Outside Counsel of record in this Action, as well as employees of said Outside Counsel working solely in legal, secretarial, clerical, and paralegal capacities and who are assisting those attorneys in this Action, and persons working for ...


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