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Mirnajafizadeh v. Air France

February 16, 2010

SEYED MOHAMMADALI MIRNAJAFIZADEH, INDIVIDUALLY, AND MRS. MIRNAJAFIZADEH, PLAINTIFFS,
v.
AIR FRANCE, TEHRAN INTERNATIONAL AIRPORT, AND DOES 1-100, INCLUSIVE, DEFENDANTS.



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

[PROPOSED] ORDER RE STIPULATED PROTECTIVE ORDER

IT IS ORDERED THAT: Good cause having been shown, and upon stipulation of the parties, the Court hereby grants the following Protective Order (hereafter "Order"), pursuant to Rule 26 of the Federal Rules of Civil Procedure:

1. DEFINITIONS AND TERMS

The following definitions and terms should apply to this Order:

2.1 Party: shall refer to Plaintiffs and/or the Defendant, Air France, in this action.

2.2 Disclosure or Discovery Material: all items or information, regardless of the medium or manner generated, stored, or maintained (including, among other things, testimony, transcripts, or tangible things) that are produced or generated in disclosures or responses to discovery in this matter.

2.3 "CONFIDENTIAL" Information or Items: For purposes of this Order, the Producing Party may designate as Confidential any information it believes to be Confidential Information, or any document containing such information. Confidential Information means any confidential and proprietary business information, and confidential personal information, including, without limitation: (1) non-public information about any individual or individuals; (2) non-public information about any client or customer of Air France; and (3) non-public, proprietary information and documents regarding Air France's policies, procedures and private information regarding Defendant's current and former agents, employees and customers.

2.4 Receiving Party: a Party that has received Disclosure or Discovery Material from a Producing Party.

2.5 Producing Party: a Party or non-party that produces Disclosure or Discovery Material in this action.

2.6 Designating Party: a Party or non-party that designates information or items that it produces in disclosures or in responses to discovery as "CONFIDENTIAL."

2.7 Protected Material: any Disclosure or Discovery Material that is designated as "CONFIDENTIAL." Protected Material includes all copies, abstracts, compilations, summaries or any other form of reproducing or capturing any of the "CONFIDENTIAL" material.

2.8 Outside Counsel: attorneys who are not employees of a Party but who are retained to represent or advise a Party in this action.

2.9. House Counsel: refers to attorneys who are employees of a Party.

2.10 Counsel (without qualifier): Outside Counsel and House Counsel (as well as their support staff).

2.11 Expert: a person with specialized knowledge or experience in a matter pertinent to the litigation who has been retained by a Party or its counsel to serve as an expert witness or as a consultant in this action and who is not a past or a current employee of a Party or of a competitor of a Party and who, at the time of retention, is not anticipated to become an employee of a Party. This definition includes a professional jury or trial consultant retained in connection with this litigation.

2.12 Professional Vendors: persons or entities that provide litigation support services (e.g., photocopying; videotaping; translating; preparing exhibits or demonstrations; organizing, storing, retrieving data in any form ...


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