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U.S. Auto Parts Network, Inc. v. Parts Geek

February 19, 2010

U.S. AUTO PARTS NETWORK, INC., A DELAWARE CORPORATION, PLAINTIFF,
v.
PARTS GEEK, LLC, A NEW JERSEY LIMITED LIABILITY COMPANY, ET AL., DEFENDANTS.



The opinion of the court was delivered by: Honorable Ralph Zarefsky United States Magistrate Judge

[PROPOSED] PROTECTIVE ORDER

[Stipulation for Protective Order filed concurrently herewith]

NOTE: CHANGES HAVE BEEN MADE TO THIS DOCUMENT

Pursuant to the Stipulation for Protective Order of Plaintiff U.S. Auto Parts Network, Inc. ("USAP") and Defendants Parts Geek, LLC, Richard E. Pine, Brian Tinari, Lowell E. Mann, Todd Daugherty, Dannie Hendershot, Cheryl M. Hendershot, and Kyle Singleton, (collectively, "Defendants"), and good cause appearing therefore, the following Protective Order is hereby entered:

1. This Protective Order shall be applicable to and govern all depositions, documents produced in response to requests for production of documents, answers to interrogatories, responses to requests for admissions, and all other discovery taken pursuant to the Federal Rules of Civil Procedure, as well as all documents produced by either party in response to informal discovery requests, and testimony adduced at trial, matters in evidence and computerized records (collectively, "RECORDS") which the disclosing party designates as "CONFIDENTIAL MATERIAL" or "FOR OUTSIDE COUNSEL'S EYES ONLY MATERIAL" hereafter furnished, directly or indirectly, by or on behalf of any party in connection with this action.

2. In designating RECORDS as "CONFIDENTIAL MATERIAL" or "FOR OUTSIDE COUNSEL'S EYES ONLY MATERIAL," a party shall make such a designation of CONFIDENTIAL MATERIAL or FOR OUTSIDE COUNSEL'S EYES ONLY MATERIAL only for RECORDS which that party in good faith believes contain trade secrets, as defined by California Civil Code § 3426.1, or other confidential, competitive or proprietary business information used by it in, or pertaining to, its business which the party takes appropriate efforts to keep confidential or which the party is otherwise required to keep confidential by agreement or law. This includes is limited to RECORDS described in the Good Cause Statement set forth in the Stipulation for Protective Order. For a designation of RECORDS as "FOR OUTSIDE COUNSEL'S EYES ONLY MATERIAL," the party must additionally believe in good faith that the RECORDS must be protected from disclosure to the parties themselves in this litigation and must be subject to the restricted disclosure provided for below. CONFIDENTIAL MATERIAL and FOR OUTSIDE COUNSEL'S EYES ONLY MATERIAL shall be used solely for the purpose of conducting this litigation and not for any other purpose.

3. RECORDS designated as CONFIDENTIAL MATERIAL may be disclosed only to the following persons:

(a) the attorneys working on this action on behalf of any party, including in-house attorneys;

(b) any paralegal assistants, stenographic and clerical employees working under the direct supervision of such counsel;

(c) any parties to this action who are individuals, and every employee, director, officer, or manager (collectively, "employee") of parties to this action who are entities other than individuals, but only to the extent necessary to further the interest of the parties in this litigation;

(d) any person not employed by a party who is expressly retained or sought to be retained by any attorney described in paragraph 3(a) to assist in preparation of this action for trial, with disclosure only to the extent necessary to perform such work;

(e) any witness at deposition or trial in this matter, provided that such witness is at the time of deposition or trial a current employee of the party who produced the RECORDS in discovery, or if not a current employee of the party who produced the RECORDS in discovery, then only upon such terms as the parties in this action may stipulate or the Court may order;

(f) any court reporter at deposition or trial in this matter, provided that such court reporter agree to maintain the confidentiality of the RECORDS; and

(g) the Court.

4. RECORDS designated as "FOR OUTSIDE COUNSEL'S EYES ONLY MATERIAL" may be disclosed only ...


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