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Gary Henley v. International Brotherhood of Electrical Workers

May 19, 2011

GARY HENLEY,
PLAINTIFF,
v.
INTERNATIONAL BROTHERHOOD OF ELECTRICAL WORKERS, AND DOES 1-50,
DEFENDANTS.



The opinion of the court was delivered by: Honorable Oliver W. Wanger

STACY A. CAMPOS, SBN 154658 PACIFIC GAS AND ELECTRIC COMPANY LAW DEPARTMENT P.O. Box 7442 San Francisco, CA 94120 KATE DYER, SBN 171891 NICOLE HOWELL NEUBERT, SBN 246078 CLARENCE & DYER LLP 899 Ellis Street San Francisco, CA 94109 Telephone: (415) 749-1800 Facsimile: (415) 749-1694 Email: kdyer@clarencedyer.com nhneubert@clarencedyer.com Attorneys for Defendant PACIFIC GAS AND ELECTRIC COMPANY

STIPULATION AND PROTECTIVE PACIFIC GAS AND ELECTRIC COMPANY, ORDER LOCAL UNION NUMBER 1245 OF

Trial Date: January 18, 2012 Time: 9:00 a.m. inclusive, Courtroom: 3, 7th Floor

Stipulation and Protective Order 1 Case No. 1:10-cv-01119-OWW-GSA ted with pdfFactory trial version www.pdffactory.com

WHEREAS the discovery and pre-trial phase of the above captioned action, Case No. 31:10-CV-01119-OWW-GSA ("Action") may involve disclosure of confidential and proprietary business, technical, financial and personal information, IT IS HEREBY ORDERED as follows:

1. DEFINITIONS (a) Party: Any named plaintiff and any defendant in this action, including all of its officers, directors, employees, consultants, retained experts, and outside counsel (and their support staff).

(b) 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.

(c) "Confidential" Information or Items: information (regardless of how generated, stored or maintained) or tangible things that qualify for protection.

(d) Receiving Party: a Party that receives Disclosure or Discovery Material from a Producing Party.

(e) Producing Party: a Party or non-party that produces Disclosure or Discovery Material in this action.

(f) Designating Party: a Party or non-party that designates information or items that it produces in disclosures or in responses to discovery as "Confidential."

(g) Protected Material: any Disclosure or Discovery Material that is designated as "Confidential"

2. This Protective Order shall govern any document which is designated "Confidential" and shall be used only by the persons specified in Paragraph 4. Any designation shall be made in good faith.

3. Absent a specific order by the Court, any document marked "Confidential" and the contents thereof, which are produced or testified to in this Action shall be used by the parties solely in connection with this Action and shall not be ...


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