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In Re Application of: the Republic of Ecuador

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA


March 14, 2011

IN RE APPLICATION OF: THE REPUBLIC OF ECUADOR, APPLICANT,

The opinion of the court was delivered by: Edward M. Chen United States Magistrate Judge

[PROPOSED] SUPPLEMENTAL PROTECTIVE ORDER

For the Issuance of a Subpoena for the ) 21 Taking of a Deposition and the Production ) of Documents In a Foreign Proceeding ) 22 Pursuant to 28 U.S.C. § 1782. ) ) 23

For good cause appearing, under Federal Rule of Civil Procedure 26(c)(1), IT IS HEREBY ORDERED that the Protective Order entered on February 25, 2011 in In re Application of The 3 Republic of Ecuador, 3:10-mc-80225 CRB (EMC) (the "Original Protective Order") is modified to 4 add the following: 5 (10) Information or items marked "Highly Confidential -- Attorneys' Eyes Only" shall, unless 6 7 otherwise ordered by the court or permitted in writing by the Designating Party, be disclosed only to:

a.) Outside Counsel for purposes of BIT litigation (as well as employees of said Applicants' Outside Counsel to whom it is reasonably necessary to disclose the information for 10 purposes of the BIT Litigation);

disclosure is reasonably necessary including for purposes of the BIT Litigation;

d.) Experts or other witnesses (1) to whom disclosure is reasonably necessary for the BIT Litigation and (2) who have signed the "Agreement to Be Bound by Protective Order" (Exhibit A), 17 and 18

e.) the author of the document or the original source of the information.

(11) Counsel for Borja shall produce a redacted copy of each document marked "Highly Confidential - Attorneys' Eyes Only" with the identities of certain persons or identifying information 21 22 for those persons redacted. Applicants shall be permitted to disclose such redacted copies to those attorneys for the Procuradura General del Estado acting as an attorney who has responsibilities in 24 conjunction with the BIT litigation. No other use for such redacted copies shall be permitted except 25 as allowed under modifications pursuant to paragraph 13 below. 26

(12) Except as set forth in Paragraphs 10 and 11 above, nothing in this supplement to the Original 27 Protective Order shall be construed as modifying the Original Protective Order. All documents 28

b.) Courts, arbitral tribunals, and their personnel for purposes of the BIT Litigation; Winston & Strawn LLP California Street San Francisco, CA 94111-5802

c.) Court reporters, interpreters, their respective staffs, and professional vendors to whom produced pursuant to this supplement shall be included in the Protected Materials covered under the Original Protective Order 3 (13) If Applicants, at any time after reviewing the documents covered by this Supplemental 4 Privilege Order, need to share the redacted information with any person not authorized to see such 5 documents under this Supplemental Protective Order, the parties will meet and confer to resolve the 6 7 issue. Applicants reserve their right to seek modification of this Supplemental Protective Order as necessary.

ES DISTRI T T S T A C C O D U E T I T R

ORDERED

IT IS SO

Winston & Strawn LLP 101 California Street San Francisco, CA 94111-5802

N N Edward M. Chen R O Judge O

R F T I H L E C A RN F DI STR CT O

20110314

© 1992-2011 VersusLaw Inc.



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