The opinion of the court was delivered by: Hon. Andrew J. Wistrich
DISCOVERY MATTER Hon. Andrew J. Wistrich PROTECTIVE ORDER BASED ON JOINT STIPULATION GOVERNING DISCLOSURE OF CONFIDENTIAL MATERIALAND RELATED COUNTERCLAIMS
Action Filed: December 10, 2010 Trial Date: April 17, 2012
WHEREAS, Plaintiff and Counter-Defendant Lifted Research Group, Inc. and Defendants and Counter-Claimants Super Sexy LLC and Coogi Menswear, LLC (collectively, the "parties") intend to produce documents and information that may contain confidential material;
WHEREAS, the parties have submitted a Joint Stipulation for Entry of Protective Order Governing Disclosure of Confidential Information (the "Stipulation"), a copy of which is attached as Exhibit A and is incorporated herein by reference; and
WHEREAS, the Court has considered the Stipulation and finds good cause to enter the requested Protective Order set forth therein;
IT IS HEREBY ORDERED that the parties' request for entry of a Protective Order as set forth in the Stipulation is GRANTED and that the Stipulation is hereby APPROVED as a Protective Order and entered this 12th day of August, 2011.
MICHAEL A. FIRESTEIN (SBN 110622) firstname.lastname@example.org
NAVID SOLEYMANI (SBN 219190) email@example.com
PROSKAUER ROSE LLP 2049 Century Park East, 32nd Floor Los Angeles, CA 90067-3206 Telephone: (310) 557-2900 Facsimile: (310) 557-2193 Attorneys for Plaintiff and Counter-Defendant LIFTED RESEARCH GROUP, INC.
RICHARD A. KOLBER (SBN 125869)
LAW OFFICES OF RICHARD A. KOLBER 2029 Century Park East, Suite 900 Los Angeles, California 90067-2910 Telephone: (310) 557-1902 Facsimile: (310) 557-1904 firstname.lastname@example.org IRA S. SACKS AKERMAN SENTERFITT LLP 335 Madison Avenue, 26th Floor New York, NY 10017 Telephone: (212) 880-3827 Facsimile: (212) 905.6458 email@example.com Attorneys for Defendants and Counter-Claimants SUPER SEXY LLC and COOGI MENSWEAR LLC
UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA LIFTED RESEARCH GROUP, INC., a California corporation,
Case No. SACV 11-00053 AG (AJWx) DISCOVERY MATTER Hon. Andrew J. Wistrich JOINT STIPULATION FOR ENTRY OF PROTECTIVE ORDER GOVERNING DISCLOSURE OF CONFIDENTIAL MATERIAL Plaintiff, v. SUPER SEXY LLC, a New York limited liability company, COOGI MENSWEAR LLC, a New York limited liability company, and DOES 1-10, inclusive, Action Filed: December 10, 2010 Trial Date: April 17, 2012 Defendants.
A. Discovery is underway in this action, and Plaintiff and Counter-Defendant Lifted Research Group, Inc. ("Plaintiff" or "LRG") and Defendants and Counter-Claimants Super Sexy LLC ("SSL") and Coogi Menswear, LLC (collectively, "Defendants") have exchanged, or will exchange, requests for production of documents and associated productions therewith, and seek to take certain depositions.
B. In order to facilitate discovery, including the production of documents that may contain confidential information, Plaintiffs and Defendants (collectively, the "parties" and, separately, "party") have agreed to enter into this Stipulation for Entry of Protective Order Governing Disclosure of Confidential Material (the "Stipulation") and to seek a Court Order incorporating the terms of the Stipulation (the "Protective Order"), as follows:
IT IS HEREBY STIPULATED, by and between the parties, through their respective attorneys of record, as follows:
1. This Stipulation and the Protective Order shall apply to all "Confidential Information" and "Attorneys' Eyes Only Information" ...