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Headley v. Church of Scientology International

July 30, 2010

MARC HEADLEY, PLAINTIFF,
v.
CHURCH OF SCIENTOLOGY INTERNATIONAL, A CORPORATE ENTITY; AND DOES 1 THROUGH 20, DEFENDANTS.
CLAIRE HEADLEY, PLAINTIFF,
v.
CHURCH OF SCIENTOLOGY INTERNATIONAL; RELIGIOUS TECHNOLOGY CENTER; AND DOES 1 THROUGH 20, DEFENDANTS.



The opinion of the court was delivered by: Margaret A. Nagle United States Magistrate Judge

[PROPOSED] PROTECTIVE ORDER CONCERNING PRODUCTION OF CONFIDENTIAL INFORMATION

NOTE: CHANGES MADE BY THE COURT

The Court having considered defendants Church of Scientology International ("CSI") and Religious Technology Center's ("RTC") Joint Motion for Protective Order Concerning the Production of Confidential Information and the parties' Joint Stipulation Regarding Plaintiffs' Motion to Compel Production of Documents and good cause appearing as set forth in defendants' Motion for Protective Order and defendants' portion of the parties' Joint Stipulation,

IT IS HEREBY ORDERED that the discovery of certain materials as described below shall be made subject to the following conditions:

1. PURPOSES AND LIMITATIONS.

This Protective Order Concerning Production of Confidential Information

("Order") does not confer blanket protections on all disclosures or responses to discovery and that the protection it affords extends only to the limited information or items that are entitled under the applicable legal principles to treatment as confidential. As set forth in Section 10, below, this Order creates no entitlement to file confidential information under seal; Local Civil Rule 79-5 sets forth the procedures that must be followed when a party seeks permission from the court to file material under seal.

2. DEFINITIONS. 2.1 Party or Parties: Any party to this action, including all of its staff, officers, directors, employees, consultants, retained experts, and counsel (and their support staff). For the purposes of this Order, Claire Headley and Marc Headley are considered Parties.

2.2 ESI: Electronically stored information, as that term is used and referred to in Fed.R.Civ.P. 26 and 34.

2.3 Disclosure or Discovery Material: All items or information, regardless of the medium or manner generated, stored, or maintained (including, without limitation, documents, ESI, testimony, transcripts, or tangible things) that are produced or generated in disclosures or responses to discovery in this matter.

2.4 "CONFIDENTIAL" Information or Items: Information (regardless of how generated, stored or maintained) or tangible things that qualify for protection under standards developed under Fed.R.Civ.P. 26(c) or pursuant to rights of privacy recognized by statute, constitution, or by common law.

2.5 "NON-POSSESSORY" Information or Items: Information that is not generally available to the public to possess or copy, including, without limitation, certain Church-related videos, lectures, and other written materials.

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

2.7 Designating Party: A Party or non-party that designates information or items that it produces in disclosures or in responses to discovery as "CONFIDENTIAL" or "NON-POSSESSORY."

2.8 Protected Material: Any Disclosure or Discovery Material that is designated as "CONFIDENTIAL" or "NON-POSSESSORY."

2.9 Receiving Party: A Party that receives Protected Material from a Producing Party.

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

2.11 House Counsel: Attorneys who are employees of a Party.

2.12 Counsel (without qualifier): Outside Counsel and House Counsel.

2.13 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. This definition includes a professional jury or trial consultant retained in connection with this litigation.

2.14 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 or medium, etc.) and their employees and subcontractors.

3. SCOPE.

The protections conferred by this Order cover not only Protected Material (as defined above), but also any information copied or extracted therefrom, as well as all copies, ...


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