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Karen Herbert, Judy Schenker, Jodi Eberhart, Cheryl v. Endemol Usa

May 25, 2011

KAREN HERBERT, JUDY SCHENKER, JODI EBERHART, CHERYL BENTLEY, AND ALL OTHERS SIMILARLY SITUATED, PLAINTIFFS,
v.
ENDEMOL USA, INC., NBC UNIVERSAL, INC., VERISIGN, INC., M-QUBE, INC. AND DON JAGODA ASSOCIATES, INC., DEFENDANTS.



The opinion of the court was delivered by: Magistrate JUDGE:Hon. Victor B. Kenton

JOINT STIPULATION FOR PROTECTIVE ORDER RE CONFIDENTIALITY AND ORDER

JUDGE: Hon. Jacqueline H. Nguyen

CTRM: 590 Complaint Filed: May 31, 2007

THIS DOCUMENT PERTAINS TO ALL CASES

IT IS HEREBY STIPULATED by the undersigned Parties, through their respective counsel and subject to the approval of the Court, that a Protective Order issue in this Action regarding certain documents and information produced during discovery.

DEFINITIONS

1. As used in this Protective Order,(a) "Action" means the case entitled Karen Herbert, el al v. Endemol USA, Inc., et al, Case No. 07-3537, along with related Case Nos. 07-3643; 07-3647; 07-3916; 07-08044; 07-8122; and 07-8196, pending in United States District Court for the Central District of California.

(b) "Confidential Material" means Material designated as CONFIDENTIAL in accordance with the terms of this Protective Order.

(c) "Designating Party" means any Party or Person who designates Material as Confidential Material.

(d) "Discovering Counsel" means counsel for a Discovering Party. (e) "Discovering Party" means the Party to whom Material is being Provided by a Producing Party.

(f) "Material" means any document, testimony or information in any form or medium whatsoever, including, without limitation, any written or printed matter provided in this action by any Party or Person before or after the date of this Protective Order.

(g) "Party" means the Parties to any case comprising the Action, their attorneys of record and their agents.

(h) "Person" means any individual, corporation, partnership, unincorporated association, governmental agency, or other business or governmental entity whether a Party or not.

(i) "Producing Party" means any Party or Person who Provides Material during the course of the Action.

(j) "Provide" means to produce Material, whether pursuant to request or process, and whether in accordance with the Federal Rules of Civil Procedure or otherwise.

CONFIDENTIAL DESIGNATION

2. A Producing Party may designate as "CONFIDENTIAL" any non-public Material which the Producing Party handles in a confidential manner, and reasonably believes is entitled to protection pursuant to applicable law. A Producing Party may designate Confidential Material for protection under this order by either of the following methods:

(a) By physically marking it with the following inscription prior to Providing it to a Party: "CONFIDENTIAL" (b) By identifying with specificity in writing to the Discovering Party, within 10 calendar days of its initial production, any previously Provided Material which was not designated as CONFIDENTIAL prior to its having been Provided. For purposes of this method of designation, it will be a sufficiently specific identification to refer to the document production (aka "Bates") numbers or deposition page numbers of previously Provided Material. Where a Producing Party designates previously Provided Material as Confidential Material pursuant to subparagraph 2(b), the Producing Party will follow the procedures set forth in subparagraph 2(a) for designating Confidential Material, and Provide to the Discovering Party additional copies of the previously Provided Material marked with the inscription described in subparagraph 2(a). Upon receipt of the additional copies which comply with the procedures set forth in the previous subparagraph, the Discovering Party will immediately return to the Producing Party the previously Provided Material, or alternatively, will destroy all the previously Provided Material, at the option and cost of the Producing Party. For previously Provided Material which was not designated as Confidential Material at the time of its being Provided, this Protective Order shall apply to such materials beginning on the date that the Producing Party makes such designation, to the extent possible. Failure to designate or identify Material as Confidential Material using the aforementioned procedures shall not operate to waive a Producing Party's right to later so designate or identify such material.

(c) The Parties may agree in writing to modify the foregoing designation procedures where compliance with them proves impracticable or very burdensome. However, no modification by the Parties shall have the force or effect of a Court order unless the Court approves the modification.

RESTRICTION ON USE OF CONFIDENTIAL MATERIAL

3. Confidential Material shall not be disclosed, nor shall its contents be disclosed, to any Person other than those described in ¶ 6 of this Protective Order and other than in accordance with the terms, conditions and restrictions of this Protective Order.

4. Confidential Material Provided by a Producing Party to a Discovering Party shall not be used by the Discovering Party or anyone other than the Producing Party, specifically including the persons identified in ΒΆ 6, as appropriate, for any purpose, including, without limitation, any personal, business, governmental, commercial, or litigation (administrative or judicial) purpose, other than the prosecution or defense of this Action. If the Producing Party stops treating the Material as confidential, then it will no longer be deemed confidential or ...


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