The opinion of the court was delivered by: Oliver W. Wanger United States District Judge
STIPULATED PROTECTIVE ORDER REGARDING PRODUCTION OF CONFIDENTIAL INFORMATION Hon. Oliver W. Wanger
WHEREAS, the parties are engaged in discovery in this case;
WHEREAS, the parties agree that there may be confidential personnel information related to Defendant's current and former employees, who are and are not parties to this action and trade secrets and other confidential research, development or commercial information related to Defendant's business that should be given the protection of a court order to prevent disclosure to persons other than those set forth below;
WHEREAS, the parties agree that public disclosure of confidential personnel information of such parties and non-parties and confidential information regarding Defendant's business operations is not necessary;
WHEREAS, the parties agree that the discovery of information regarding confidential personnel information of such parties and non-parties and Defendant's proprietary business operations may be permissible in this case and that some information may be relevant or reasonably calculated to lead to the discovery of admissible evidence; and
WHEREAS, the parties agree and stipulate to this Protective Order and stipulate that good cause exists to enter this Protective Order pursuant to Fed. R. Civ. P. 26(c);
IT IS, THEREFORE, HEREBY ORDERED THAT:
1. The Scope of the Order:
a. The terms "confidential personnel information" shall mean any information related to an individual's employment with Defendant, whether current or past, concerning the individual's wages, hours or terms and conditions of employment, including but not limited to any disciplinary records or medical records;
b. The terms "trade secrets" or "other confidential research, development or commercial information" are used in this Order in the same sense that the terms are used in Fed. R. Civ. P. 26(c)(1).
c. The terms of this Protective Order shall apply to all confidential documents produced by Plaintiffs and Defendant in this case, any of the parties' interrogatory answers designated confidential and information gathered, obtained, recorded, analyzed or summarized by the parties' counsel and/or the parties' expert witnesses, including any expert reports or other written materials prepared by the parties' expert witnesses in connection with the above-captioned cases.
2. Designation of Information and Documents.
a. The parties may designate in writing as confidential any information or documents they claim falls under the provisions of paragraph 1(a) and (b) of this Order.
b. In the event that either party disputes the Designating Party's designation of information as set forth in paragraph 2(a) of this Order, the party challenging the designation shall first contact the Designating Party's counsel and confer in good faith regarding a resolution of the dispute. If such conference does not produce a ...