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Shahriar Almasi, An Individual, Gadri Corporation, A California Corporation, Hui v. Equilon Enterprises

April 5, 2011

SHAHRIAR ALMASI, AN INDIVIDUAL, GADRI CORPORATION, A CALIFORNIA CORPORATION, HUI
ENTERPRISE, INC., A CALIFORNIA CORPORATION,
RAM JETHANI, AN INDIVIDUAL, PSS ENTERPRISES, INC., A CALIFORNIA CORPORATION, THEREON JERRY ROSS, AN INDIVIDUAL, JAGMOHAN S. SAHNI, GURPREET S. SETHI AND DEEPA K.
SETHI, INDIVIDUALS, T.P. & E., INC., A CALIFORNIA CORPORATION PLAINTIFFS,
v.
EQUILON ENTERPRISES, LLC, A DELAWARE LIMITED LIABILITY COMPANY, AND DOES 1 THROUGH 100, INCLUSIVE, DEFENDANTS.



The opinion of the court was delivered by: Judge: Hon. James Ware

WILSON TURNER KOSMO LLPROBIN A. WOFFORD (137919) JOCELYN D. HANNAH (224666) 550 West C Street, Suite 1050 San Diego, California 92101 Telephone: (619) 236-9600 Facsimile: (619) 236-9669 rwofford@wilsonturnerkosmo.com jhannah@wilsonturnerkosmo.com Attorneys for Defendant EQUILON ENTERPRISES LLC THOMAS P. BLEAU (152945) MEGAN A. CHILDRESS (266926) BLEAU FOX, A P.L.C. 3575 Cahuenga Boulevard West, Suite 580 Los Angeles, California 90068 Telephone: (323) 874-8613 Facsimile: (323) 874-1234 11 e-mail: bleaushark@aol.com e-mail: mchildress@bleaufox.com Attorneys for Plaintiffs SHAHRIAR ALMASI, et al.

Complaint Filed: June 18, 2010

Trial Date: Not Set

Dept.:

STIPULATION FOR PROTECTIVE ORDER AND ORDER

Mag. Judge: Hon. Paul Singh Grewal

1. PURPOSES AND LIMITATIONS

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 may 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 the protection it affords from public disclosure and use extends only to the limited information or items that are entitled to confidential treatment under the applicable legal principles. The parties further acknowledge, as set forth in Section 14.4, below, that this Stipulated Protective Order does not entitle them to file confidential information under seal;

Civil Local Rule 79-5 sets forth the procedures that must be followed and the standards that will be 18 applied when a party seeks permission from the court to file material under seal.

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

generated, stored or maintained) or tangible things that qualify for protection under Federal Rule of 2.3 Counsel (without qualifier): Outside Counsel of Record and House Counsel (as well as their support staff).

Upon agreement of counsel for Defendant Equilon Enterprises, LLC, ("Equilon" or "Defendant") and Plaintiffs SHAHRIAR ALMASI, an individual, GADRI CORPORATION, a INC., a California Corporation, JERRY ROSS, an individual, JAGMOHAN S. SAHNI, GURPREET ("Plaintiffs"), and deeming it just and proper to do so, IT IS HEREBY ORDERED that:

2. DEFINITIONS

2.2 "CONFIDENTIAL" Information or Items: information (regardless of how it is produces in disclosures or in responses to discovery as "CONFIDENTIAL" or "HIGHLY

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 things, testimony, 6 transcripts, and tangible things), that are produced or generated in disclosures or responses to 7 discovery in this matter.

the litigation who (1) has been retained by a Party or its counsel to serve as an expert witness or as a 10 consultant in this action, (2) is not a past or current employee of a Party or of a Party's competitor, 11 and (3) at the time of retention, is not anticipated to become an employee of a Party or of a Party's 12 competitor.

extremely sensitive "Confidential Information or Items," disclosure of which, to another Party or Non-Party would create a substantial risk of serious harm that could not be avoided by less restrictive means.

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

entity not named as a Party to this action.

but are retained to represent or advise a party to this action and have appeared in this action on 23 behalf of that party or are affiliated with a law firm which has appeared on behalf of that party.

consultants, retained experts, and Outside Counsel of Record (and their support staffs).

Material in this action.

2.4 Designating Party: a Party or Non-Party that designates information or items that it

CONFIDENTIAL - ATTORNEYS' EYES ONLY." 4

2.6 Expert: a person with specialized knowledge or experience in a matter pertinent to

2.7 "HIGHLY CONFIDENTIAL - ATTORNEYS'EYES ONLY" Information or Items:

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

2.9 Non-Party: any natural person, partnership, corporation, association, or other legal

2.10 Outside Counsel of Record: attorneys who are not employees of a party to this action

2.11 Party: any party to this action, including all of its officers, directors, employees,

2.12 Producing Party: a Party or Non-Party that produces Disclosure or Discovery

2.13 Professional Vendors: persons or entities that provide litigation support services (e.g., photocopying, videotaping, translating, preparing exhibits or demonstrations, and organizing, 3 storing, or retrieving data in any form or medium) and their employees and subcontractors.

2.14 Protected Material: any Disclosure or Discovery Material that is designated as "CONFIDENTIAL," or as "HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY."

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

defined above), but also (1) any information copied or extracted from Protected Material; (2) all 11 copies, excerpts, summaries, or compilations of Protected Material; and (3) any testimony, conversations, or presentations by Parties or their Counsel that might reveal Protected Material.

However, the protections conferred by this Stipulation and Order do not cover the following 14 information: (a) any information that is in the public domain at the time of disclosure to a Receiving Party or becomes part of the public domain after its disclosure to a Receiving Party as a result of 16 publication not involving a violation of this Order, including becoming part of the public record 17 through trial or otherwise; and (b) any information known to the Receiving Party prior to the 18 disclosure or obtained by the Receiving Party after the disclosure from a source who obtained the 19 information lawfully and under no obligation of confidentiality to the Designating Party. Any use of

4. DURATION

Even after final disposition of this litigation, the confidentiality obligations imposed by this Order shall remain in effect until a Designating Party agrees otherwise in writing or a court order 24 otherwise directs. Final disposition shall be deemed to be the later of (l) dismissal of all claims and 25 defenses in this action, with or without prejudice; and (2) final judgment herein after the completion 26 and exhaustion of all appeals, rehearings, remands, trials, or reviews of this action, including the 27 time limits for filing any motions or applications for extension of time pursuant to applicable law.

3. SCOPE

The protections conferred by this Stipulation and Order cover not only Protected Material (as Protected Material at trial shall be governed by a separate agreement or order.

must take care to limit any such designation to specific material that qualifies under the appropriate 5 standards. To the extent it is practical to do so, the Designating Party must designate for protection 6 only those parts of material, documents, items, or oral or written communications that qualify - so 7 that other portions of the material, documents, items, or communications for which protection is not 8 warranted are not swept unjustifiably within the ambit of this Order.

to be clearly unjustified or that have been made for an improper purpose (e.g., to unnecessarily 11 encumber or retard the case development process or to impose unnecessary expenses and burdens on other parties) expose the Designating Party to sanctions.

protection do not qualify for protection at all or do not qualify for the level of protection initially asserted, that Designating Party must promptly notify all other parties that it is withdrawing the 16 mistaken designation.

(see, e.g., second paragraph of section 5.2(a) below), or as otherwise stipulated or ordered,

5. DESIGNATING PROTECTED MATERIAL

5.1 Exercise of Restraint and Care in Designating Material for Protection.

Each Party or Non-Party that designates information or items for protection under this Order Mass, indiscriminate, or routinized designations are prohibited. Designations that are shown If it comes to a Designating Party's attention that information or items that it designated for

5.2 Manner and Timing of Designations. Except as otherwise provided in this Order Disclosure or Discovery Material that qualifies for protection under this Order must be clearly so 20 designated before the material is disclosed or produced.

(a) for information in documentary form (e.g., paper or electronic documents, but

23 excluding transcripts of depositions or other pretrial or trial proceedings), that the Producing Party 24 affix the legend ONLY" to each page that contains protected material. If only a portion or portions of the material on 26 a page qualifies for protection, the Producing Party also must clearly identify the protected portion(s) (e.g., by making appropriate markings ...


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