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Reiter v. Mutual Credit Corp.

December 18, 2009

PATRICIA C. REITER AN INDIVIDUAL AND CHRISTOPHER J. REITER AND JAMES A. SINGLER, AS SUCCESSOR TRUSTEE OF THE JACK L. REITER AND PATRICIA C. REITER IRREVOCABLE TRUST, U/A/D/ AUGUST 27, 2000, PLAINTIFFS,
v.
MUTUAL CREDIT CORPORATION, SPURLING GROUP, LLC , SPURLING GROUP II, LLC, MICHAEL BROWN, ANTHONY JACOBSON, DAVID DOTEN, RUMSON CAPITAL, L.P., NATIONAL WEALTH ADVISORS, RICHARD L. SWOPE, SWOPE LAMBERSON, P.A., TODD SHELBAUGH AND DOES 1 THROUGH 100, DEFENDANTS.



The opinion of the court was delivered by: Robert N. Block United States Magistrate Judge

PROTECTIVE ORDER REGARDING CONFIDENTIALITY

Date Action Filed: July 14, 2009

Consistent with the stipulation of parties, pursuant to the court's authority under Fed. R. Civ. P. 26(c), and in order to protect the confidentiality of confidential information obtained by the parties in connection with this case, the court hereby orders:

Designation of Confidential Information

1. Any party or non-party may designate as Confidential any document or response to discovery which that party or non-party considers in good faith to contain information involving trade secrets, medical information, confidential business or financial information, or any other confidential, proprietary, or otherwise sensitive information that is subject to protection under California law, federal law, or any other applicable state law ("Confidential Information" or "Confidential Documents"). Any party may designate any document or portion of a document as Confidential pursuant to this Protective Order by any of the following methods: (a) by stamping the relevant page with the designation "Confidential;" or (b) by affixing the legend "Confidential" on the cover of any multi-page document which shall designate all pages of the document as Confidential.

2. Except with the prior written consent of the party or non-party originally designating a document as confidential, or as hereinafter provided under this Protective Order, no Confidential Information or Documents may be disclosed to any person, including, but not limited to, any party, law firm, or their agents involved in litigation with any defendant, other than those directly involved in the above-captioned matter.

3. The parties agree that Confidential Information obtained through discovery in this action shall be used solely by the parties to this litigation for purposes of this action. This provision shall not be construed as a waiver of the right of any party to seek Confidential Information in any other action or arbitration, including the same Confidential Information obtained through discovery in this action.

Permissible Disclosures

4. Notwithstanding ¶2, Confidential Information or Documents can be disclosed to following individuals or entities only to the extent necessary for this litigation:

a. counsel for the respective parties to this litigation, including in-house counsel and co-counsel retained for this litigation;

b. employees of such counsel;

c. parties, including any officer, agent, or employee (current or former) of a party, to the extent deemed necessary by counsel for the prosecution or defense of this litigation;

d. consultants or expert witnesses retained for the prosecution or defense of this litigation;

e. any authors, custodians, or recipients of the Confidential Information or Documents;

f. the Court (including appellate courts), arbitrators, and mediators, and the personnel ...


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