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The Hebrew University of Jerusalem v. General Motors Company

December 28, 2010


ARENT FOX LLP Steven E. Bledsoe (State Bar No. 157811) David G. Bayles (State Bar No. 208112) 555 West Fifth Street, 48th Floor Los Angeles, CA 90013-1065 Telephone: 213.629.7400 Facsimile: 213.629.7401 Email: Email: Anthony V. Lupo (Admitted Pro Hac Vice) 1050 Connecticut Avenue, NW Washington, D.C. 20036 Telephone: 202.857.6000 Facsimile: 202.857.6395 E-mail: Attorneys for Plaintiff THE HEBREW UNIVERSITY OF JERUSALEM DAVIS WRIGHT TREMAINE LLP Kelli L. Sager (State Bar No. 120162)

Lisa Kohn (State Bar No. 260236) 865 S. Figueroa Street, Suite 2400 Los Angeles, California 90017-2566 Telephone: (213) 633-6800 Facsimile: (213) 633-6899 Email: Email: Attorneys for Defendant GENERAL MOTORS COMPANY (Counsel continued on next page)


(Counsel continued from previous page) DAVIS WRIGHT TREMAINE LLP Stephen M. Rummage (admitted pro hac vice) Ambika K. Doran (admitted pro hac vice) 1201 Third Avenue, Suite 2200 Seattle, Washington 98101 Telephone: (206) 757-8136 Facsimile: (206) 757-7136 Email: Email: Attorneys for Defendant GENERAL MOTORS COMPANY



Disclosure and discovery activity in this action are likely to involve production of confidential, proprietary, or private information for which special protection from public disclosure and from use for any purpose other than prosecuting this litigation would be warranted. Accordingly, the parties hereby stipulate to and petition the court to enter the following Stipulated Protective Order. The parties acknowledge that this Order does not confer blanket protections on all disclosures or responses to discovery and that it affords protection only to the limited information or items entitled to treatment as confidential under applicable legal principles. The parties further acknowledge, as set forth in Section 10, below, that this Stipulated Protective Order creates no entitlement to file confidential information under seal; Civil Local Rule 79-5 sets forth the procedures that the parties must follow and reflects the standards that the Court will apply when a party seeks permission from the Court to file material under seal.


2.1 Party: any party to this action, including all of its officers, directors, employees, consultants, retained experts, insurers, and outside counsel (and their support staff), and any indemnitor providing a defense in this action on behalf of a party.

2.2 Disclosure or Discovery Material: all items or information, regardless of the medium or manner generated, stored, or maintained (including, among other things, testimony, transcripts, or tangible things) that are produced or generated in disclosures or responses to discovery in this matter.

2.3 "Confidential" Information or Items: information (regardless of how generated, stored or maintained) or tangible things that qualify for protection under the standards developed under either FRCP 26(c) or the definition of "trade secret" identified in California Civil Code § 3426.1, which provides that trade secret "means information, including a formula, pattern, compilation, program, device, method, technique, or process, that: (1) Derives independent economic value, actual or potential, from not being generally known to the public or to other persons who can obtain economic value from its disclosure or use; and (2) Is the subject of efforts that are reasonable under the circumstances to maintain its secrecy." Among other things, the parties anticipate that that Confidential Information will include financial information (such as insurance policies, financial statements, and other records of income and expenses), as well as other commercial information that has value by virtue of its non-public nature, such as customer information.

2.4 "Highly Confidential -- Attorneys' Eyes Only" Information or Items: extremely sensitive "Confidential Information or Items" whose disclosure to another Party or non-party would create a substantial risk of serious injury, including competitive injury, that could not be avoided by less restrictive means.

2.5 Receiving Party: a Party that receives Disclosure or Discovery Material from a Producing Party.

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 "Highly Confidential - Attorneys' Eyes Only."

2.8 Protected Material: any Disclosure or Discovery Material that is designated as "Confidential" or as "Highly Confidential -- Attorneys' Eyes Only."

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

2.10 House Counsel: attorneys who are employees of a Party.

2.11 Counsel (without qualifier): Outside Counsel and House Counsel, as well as their support staffs.

2.12 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 and who is not a current employee of a Party or of a competitor of a Party and who, at the time of retention, is not anticipated to become an employee of a Party or a competitor of a Party. This definition includes a professional jury or trial consultant retained in connection with this litigation.

2.13 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.


The protections conferred by this Stipulation and Order cover not only Protected Material (as defined above), but also any information copied or extracted therefrom, as well as all copies, excerpts, summaries, or compilations thereof, plus testimony, conversations, or presentations by parties or counsel in settings other than open court, that might reveal Protected Material.


Even after the termination of this litigation, the confidentiality obligations imposed by this Order shall remain in effect until a Designating Party agrees otherwise in ...

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