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Luis Polanco, An Individual v. Schneider National Carriers

December 1, 2010

LUIS POLANCO, AN INDIVIDUAL; ALAN KRUMBINE, AN INDIVIDUAL; ASUNCION ARIAS, AN INDIVIDUAL, ON BEHALF OF THEMSELVES AND ALL OTHERS SIMILARLY SITUATED, PLAINTIFFS,
v.
SCHNEIDER NATIONAL CARRIERS, INC., A NEVADA CORPORATION; AND DOES 1 THROUGH 50, INCLUSIVE, DEFENDANTS.



[PROPOSED] PROTECTIVE ORDER REGARDING CONFIDENTIAL INFORMATION Complaint Filed: February 5, 2010 Trial Date: None Set Judge: Hon. George H. King

Case No. CV-10-04565 GHK (JEMx) [PROPOSED] PROTECTIVE ORDER REGARDING CONFIDENTIAL INFORMATION

PROTECTIVE ORDER

Pursuant to the parties' stipulation and good cause appearing, the Court hereby approves this Protective Order. The Protective Order shall govern handling of the parties' Confidential Information, Highly Confidential Information, and Privileged Information, and Work Product Information, as those terms are defined below.

DEFINITIONS

1. As used in this Protective Order, "Confidential Information" means information that a party believes constitutes trade secrets or other confidential business, financial, research, development, or commercial information, or non-public information concerning individuals, and that the party in good faith believes, given its nature, should be afforded confidential treatment and which the parties would not disclose but for the entry of this Protective Order. When designating information or materials as Confidential in accordance with this Protective Order, the designating party shall use the designation "Confidential."

2. As used in this Protective Order, "Highly Confidential Information" means extremely sensitive Confidential Information whose disclosure to another party or nonparty would create a substantial risk of serious injury that could not be avoided by less restrictive means. When designating information or materials as Highly Confidential in accordance with this Protective Order, the designating party shall use the designation "Highly Confidential -- Attorneys' Eyes Only."

3. As used in this Protective Order, "Privileged Information" means information protected from disclosure pursuant to an applicable legal privilege, such as the attorney-client privilege.

4. As used in this Protective Order, "Work Product Information" means information protected from disclosure pursuant to the attorney work product doctrine.

CONFIDENTIAL AND HIGHLY CONFIDENTIAL INFORMATION

5. The parties may designate as "Confidential" or "Highly Confidential -- Attorneys' Eyes Only" and thereby subject to the terms of this protective order any materials, in any form, referring to the contents of Confidential Information or Highly Confidential Information as follows:

(a) If Confidential Information or Highly Confidential Information are referred to in a document (as defined in Evidence Code section 250) and produced by the party seeking to designate it as Confidential or Highly Confidential, the party shall mark the face of each page of the document "Confidential" or "Highly Confidential -- Attorneys' Eyes Only" respectively. If a document referring to the contents of Confidential Information or Highly Confidential Information is produced by someone other than the party seeking to designate the document as Confidential or Highly Confidential, the party seeking to designate the document as Confidential or Highly Confidential shall designate the document as such by notifying the other parties to the action in writing that it considers the document to contain Confidential Information or Highly Confidential Information and the adverse parties receiving the document shall treat it as Confidential (or Highly Confidential if designated as such), and take steps they deem reasonably necessary to ensure that others who have received the document treat it as Confidential (or Highly Confidential if designated as such). The parties may agree to designate as "Confidential" or "Highly Confidential -- Attorneys' Eyes Only" any document produced prior to the date of this Protective Order.

(b) If a discovery response referring to the contents of Confidential Information or Highly Confidential information is made by someone other than the party seeking Confidential or Highly Confidential treatment, the party seeking to designate the response as Confidential or Highly Confidential shall designate the response as such by notifying the other parties to the action in writing that it considers the response to contain Confidential Information or Highly Confidential Information and the adverse parties receiving the response shall treat it as Confidential (or Highly Confidential if designated as such) and take steps they deem reasonably necessary to ensure that others who have received the response treat it as Confidential (or Highly Confidential if designated as such). If the contents of Confidential Information or Highly Confidential Information are referred to in discovery responses by the party seeking Confidential or Highly Confidential treatment, the party shall designate the response as Confidential or Highly Confidential when responding to the request. The parties may agree to designate as "Confidential" or "Highly Confidential -- Attorneys' Eyes Only" any such response given prior to the date of this Protective Order.

(c) If the contents of Confidential Information or Highly Confidential Information are referred to in testimony in any proceeding in this action, the party seeking to designate the testimony as Confidential or Highly Confidential shall do so on the record at the time the testimony is given or by giving written notice to the parties within a reasonable time after the designating party's receipt of the transcript containing such testimony. "Reasonable time" shall normally be 30 days from the designating party's receipt of the transcript containing such testimony. The parties shall cooperate in allowing longer or shorter periods of time as needs of the case arise.

6. Unless otherwise agreed, the parties shall use each other's Confidential Information and Highly Confidential Information produced in this Action solely for purposes of the above-captioned action (the "Action") or any related legal proceedings, and shall not use such Confidential Information or Highly Confidential Information for any other purpose or in any other action or litigation, and shall not disclose, communicate, produce, or otherwise make such Confidential Information or Highly Confidential Information available to anyone except as specified in this Protective Order. Nothing in this Protective Order shall prevent or restrict a party from using, disclosing, producing, communicating or otherwise making available their own Confidential Information or Highly Confidential Information as it deems appropriate.

7. "Qualified Persons" to whom Confidential Information may be disclosed, communicated, produced or otherwise made available are:

(a) Attorneys of record for any party in this action and their associated lawyers, legal assistants, secretarial and clerical personnel engaged in assisting them in this litigation and who shall be ...


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