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Patricia White v. Coblentz

March 18, 2011

PATRICIA WHITE,
PLAINTIFF,
v.
COBLENTZ, PATCH, DUFFY & BASS, LLP LONG TERM DISABILITY INSURANCE
DEFENDANT. THE PRUDENTIAL INSURANCE
COMPANY OF AMERICA, REAL PARTY IN INTEREST.



The opinion of the court was delivered by: Judge: Hon. Bernard Zimmerman

TAD A. DEVLIN (SBN: 190355) JOEL A. MORGAN (SBN: 262937) 2 GORDON & REES LLP 275 Battery Street, Suite 2000 3 San Francisco, CA 94111 Telephone: (415) 986-5900 4 Facsimile: (415) 986-8054 5 Attorneys for Defendants COBLENTZ, PATCH, DUFFY & BASS, LLP LONG TERM DISABILITY INSURANCE PLAN, And THE PRUDENTIAL INSURANCE CO. OF AMERICA, 7 Real Party in Interest 8 LAURENCE F. PADWAY (SBN: 089314) LAW OFFICES OF LAURENCE F. PADWAY 1516 Oak Street, Suite 109 10 Alameda, CA 94501 Telephone: (510) 814-0680 11 Facsimile: (510) 814-0650 12 Attorneys for Plaintiff, PATRICIA WHITE

Courtroom: G PLAN,

STIPULATED PROTECTIVE ORDER

1. PURPOSES AND LIMITATIONS

Disclosure and discovery activity in this action are likely to involve production of 28 confidential, proprietary, or private information for which special protection from public disclosure and from use for any purpose other than prosecuting this litigation may be warranted. 2

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 4 protections on all disclosures or responses to discovery and that the protection it affords from 5 public disclosure and use extends only to the limited information or items that are entitled to 6 confidential treatment tinder the applicable legal principles. The parties further acknowledge, as 7 set forth in Section 12.3, below, that this Stipulated Protective Order does not entitle them to file 8 confidential information under seal; Civil Local Rule 79-5 sets forth the procedures that must be 9 followed and the standards that will be applied when a party seeks permission from the court to 10 file material under seal.

2. DEFINITIONS

2.1Challenging, Party: a Party or Non-Party that challenges the designation of information or items under this Order.

2.2 "CONFIDENTIAL" Information or Items: information (regardless of how it is generated, stored or maintained) or tangible things that qualify for protection under Federal Rule of Civil Procedure 26(e).

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2.3 Counsel (without qualifier): Outside Counsel of Record and House Counsel (as well as their support staff).

2.4 Designating, Party: a Party or Non-Party that designates information or items that it produces in disclosures or in responses to discovery as "CONFIDENTIAL."
2.5 Disclosure or Discovery Material: all items or information, regardless of the medium or manner in which it is generated, stored, or maintained (including, among other 23 things, testimony, transcripts, and tangible things), that are produced or generated in disclosures 24 or responses to discovery in this matter.
2.6 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 27 witness or as a consultant in this action.

2.7 House Counsel: attorneys who are employees of a party to this action.

House Counsel does not include Outside Counsel of Record or any other outside counsel.

2.8 Non-Party: any natural person, partnership, corporation, association, or other legal entity not named as a Party to this action. 4

2.9 Outside Counsel of Record: attorneys who are not employees of a party to this action but are retained to represent or advise a party to this action and have appeared in this 6 action on behalf of that party or are affiliated with a law firm which has appeared on behalf of 7 that party.

2.10 Party: any party to this action, including all of its officers, directors, employees, consultants, retained experts, and Outside Counsel of Record (and their support 10 staffs).

2.11 Producing Party: a Party or Non-Party that produces Disclosure or Discovery Material in this action.

2.12 Professional Vendors: persons or entities that provide litigation support services (e.g., photocopying, videotaping, translating, preparing exhibits or demonstrations, and organizing, storing, or retrieving data in any form or medium) and their employees and subcontractors.

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