STIPULATED PROTECTIVE ORDER REGARDING CONFIDENTIAL DISCOVERY MATERIALS
Pursuant to the provisions of Rule 26 of the Federal Rules of Civil Procedure, Plaintiff Maxine DeVillefranche and Defendant HSBC Bank Nevada, N.A., through their counsel, entered into a Stipulation to reasonably preserve the confidentiality of discovery materials produced or information otherwise disclosed by the parties during the course of discovery in this action.
IT IS HEREBY ORDERED that, pursuant to the parties' Stipulation, the following provisions shall govern confidential information produced by the parties during the course of this action:
1. This Stipulation and Protective Order shall apply to all materials and information designated as confidential under paragraph 2 and produced by the parties during the course of discovery, and all copies, excerpts, or summaries of the documents produced, including, without limitation, documents and information produced pursuant to Rules 26, 33 or 34 of the Federal Rules of Civil Procedure, or by informal request or agreement, answers to interrogatories or requests for admissions, documents subpoenaed in connection with deposition testimony, and deposition transcripts (hereinafter referred to collectively as "Discovery Materials").
2. Any party who produces or discloses any information in discovery may designate materials or portions thereof not previously disclosed to the public by the producing party and not subject to another protective or confidentiality order as "CONFIDENTIAL." Discovery Materials that may be designated as "CONFIDENTIAL" are limited to: (1) financial information not publicly filed with any federal or state regulatory authority or otherwise publicly available; (2) trade secret information as defined under California Civil Code § 3426.1; (3) tax, medical, or other personal information (including, without limitation, social security numbers) relating to any person or entity; (4) proprietary sales, marketing, licensing, operational or other proprietary information not otherwise publicly available; (5) information pertaining to Defendant's customers that is not publicly available; and (6) information relating to non-public administrative or regulatory proceedings.
3. Documents designated "CONFIDENTIAL" included as part of any court filing shall be filed manually according to the procedures defined in Local Rule 79-5, and not by electronic means, sealed in envelopes in compliance with Local Rule 79-5 as set forth in Paragraph 9. Any non-party from whom discovery material is sought in this case may also designate the discovery material produced as "CONFIDENTIAL" as provided in this Stipulation and Protective Order.
4. Confidential Discovery Materials shall not be disclosed by any means to any person or entity for any other purpose whatsoever except the prosecution or defense of this case.
5. Confidential Discovery Materials may only be disclosed to the following persons:
(a) Attorneys of record or in-house counsel for the parties in this action and the staff of their respective law firms or in-house legal departments working on this case;
(b) Experts or consultants for each side retained for the purpose of assisting counsel in the prosecution or defense of this litigation or testifying at trial, to the extent deemed necessary in good faith by the retaining counsel to enable a consultant or expert to evaluate the proposed retention and/or provide such assistance or testimony (plus such clerical personnel of each such consultant or expert required to carry out duties assigned to them by each consultant or expert);
(c) Named parties, or officers, directors, partners, and employees of a party who are reasonably necessary to assist counsel in this case;
(d) Persons noticed for depositions or designated as trial witnesses (and their counsel, if any) to the extent reasonably deemed by counsel to be necessary in good faith in connection with that person's testimony or counsel's preparation of their case;
(e) The Court and Court personnel in accordance with the procedures set forth in Local Rule 79-5 and Paragraph 9 below;
(f) Stenographic reporters engaged for depositions or other proceedings necessary for the conduct of this case;
(g) Outside photocopying, data processing or graphic services employed by a party or its counsel to ...