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Susan Novak, An Individual and On Behalf of All Others Similarly Situated v. the Boeing Company

December 20, 2010

SUSAN NOVAK, AN INDIVIDUAL AND ON BEHALF OF ALL OTHERS SIMILARLY SITUATED AND THE GENERAL PUBLIC, PLAINTIFF,
v.
THE BOEING COMPANY, A DELAWARE CORPORATION AND DOES 1 THROUGH 100, INCLUSIVE. DEFENDANTS.



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

JOINT STIPULATION GOVERNING THE DESIGNATION AND HANDLING OF CONFIDENTIAL MATERIALS; [PROPOSED] ORDER

WHEREAS, in the course of this action, disclosure may be sought or made of information which the parties or a third-party regard as being confidential, private, a trade secret, or proprietary in nature; and

WHEREAS, the parties desire to establish a mechanism to protect and regulate the disclosure and use of such confidential, private, trade secret, or proprietary information in this action.

IT IS HEREBY STIPULATED by and between Plaintiffs SUSAN NOVAK, on behalf of herself and all putative class members she purports to represent ("Plaintiff"), and Defendant THE BOEING COMPANY ("Defendant"), by and through their attorneys of record, that the following should govern the disclosure of confidential, private, trade secret, and proprietary information in this action during the course of discovery, and respectfully jointly request the Court to enter this Proposed Order Governing the Designation and Handling of Confidential Materials (the "Order").

I. DEFINITONS

For purposes of this Stipulation, the following definitions shall apply:

a. "Party" means every party to this action, as well as any third-party, and every director, officer, current or former employee and agent of every party or third-party.

b. "CONFIDENTIAL" is a designation that any Party may apply to information which it believes in good faith to constitute, contain, reveal or reflect private, confidential or privileged information protected by applicable California and/or federal law, such as employee medical records, compensation, salary, personnel records, personal contact information, trade secrets, and other confidential research, development, commercial or personal information relating to its business or which was disclosed to it in confidence by any third-party, the disclosure of which to the general public or the adverse party could adversely prejudice that Party.

c. "Confidential Information" means any information which is properly designated "CONFIDENTIAL" as described above.

d. Exceptions to confidentiality status. Information will not be deemed "CONFIDENTIAL," and the Parties shall use reasonable efforts to ensure that information is not designated as such, if the content or substance thereof:

1. Is at the time of disclosure, or subsequently becomes through no wrongful act or failure to act on the part of the receiving Party, generally available to the relevant public; or

2. Is disclosed to the receiving Party by a third-party without breach of an obligation of confidence.

e. "Designating Party" means any Party disclosing during this action information which is designated "CONFIDENTIAL" by said Party.

f. "Counsel of Record" includes the following law firms and any law firms retained by a third-party in connection with disclosure of Confidential Information hereunder, including all attorneys, paralegals, professionals, clerks, and secretaries employed by such law firms:

1. PAYNE & FEARS LLP

2. MAKAREM & ...


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