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Jorge Iniestra, An Individual, Maria Iniestra, An Individual, J.I., A v. Cliff Warren Investments

August 19, 2011

JORGE INIESTRA, AN INDIVIDUAL, MARIA INIESTRA, AN INDIVIDUAL, J.I., A MINOR BY AND THROUGH HIS GUARDIAN AD LITEM JORGE INIESTRA; I.I. A MINOR BY AND THROUGH HIS GUARDIAN AD LITEM JORGE INIESTRA; N.I. A MINOR BY AND THROUGH HIS GUARDIAN AS LITEM JORGE INIESTRA; JESUS DORADO, AN INDIVIDUAL, MARIA DEL REFUGIO DORADO, AN INDIVIDUAL, I.D., A MINOR BY AND THROUGH HIS GUARDIAN AD LITEM MARIA DEL REFUGIO DORADO; J.D., A MINOR BY AND THROUGH HIS GUARDIAN AD LITEM MARIA DEL REFUGIO DORANDO; G.D., A MINOR BY AND THROUGH HIS GUARDIAN AD LITEM MARIA DEL REFUGIO DORANDO, PLAINTIFFS,
v.
CLIFF WARREN INVESTMENTS, INC., A CALIFORNIA CORPORATION; GEORGE H. BRETT, AN INDIVIDUAL, AND DOES 1 THROUGH 10, DEFENDANTS.



The opinion of the court was delivered by: Robert N. Block, Magistrate Judge United States District Court

RIDOUT & LYON, LLP CHRISTOPHER P. RIDOUT (State Bar No. 143931) Email: c.ridout@ridoutlyonlaw.com DEVON M. LYON (State Bar No. 218293) Email: d.lyon@ridoutlyonlaw.com BRIAN D. JOHNSON (State Bar No. 266513) Email: b.johnson@ridoutlyonlaw.com 555 E. Ocean Blvd., Ste. 500 Long Beach, California 90802 (562) 216-7380 (562) 216-7385 Fax Attorney for Defendants, CLIFF WARREN INVESTMENTS, INC. A California Corporation, and GEORGE H. BRETT, an Individual

Assigned for all purposes to the Honorable Andrew J. Guilford Assigned for Discovery purposes to the Honorable Robert N. Block

STIPULATED PROTECTIVE ORDER OF CONFIDENTIALITY [PROPOSED]

Trial Date: TBD Department: 1D

STIPULATION

Pursuant to the Federal Rules of Civil Procedure and the Court's Local Rules, the parties, plaintiffs JORGE INIESTRA, MARIA INIESTRA, J.I., a minor by and through his GUARDIAN AD LITEM JORGE INIESTRA; I.I. a minor by and through his GUARDIAN AD LITEM JORGE INIESTRA; N.I. a minor by and through his GUARDIAN AS LITEM JORGE INIESTRA; JESUS DORADO, MARIA DEL REFUGIO DORADO, I.D., a minor by and through his GUARDIAN AD LITEM MARIA DEL REFUGIO DORADO; J.D., a minor by and through his GUARDIAN AD LITEM MARIA DEL REFUGIO DORANDO; G.D., a minor by and through his GUARDIAN AD LITEM MARIA DEL REFUGIO DORANDO (hereinafter collectively "Plaintiffs") and defendants Cliff Warren Investments, Inc. and George H. Brett (hereinafter collectively "Defendants"), hereto submit the following [Proposed] Stipulated Protective Order of Confidentiality ("Order"). Under this Order, it is stipulated and agreed by and between the parties hereto, through their respective counsel and subject to the approval of the Court, that the following Order shall govern discovery and disclosures in this action. The parties agree and make such stipulation without waiving any claims or defenses in this action and without acknowledging the propriety of any claim by any party that any information produced during discovery in this action constitutes confidential information, as defined in Paragraph 3.1. This Order and the procedures herein shall not affect the rights of the parties to object to discovery on any grounds, nor shall it relieve the parties of the necessity of proper response or objection to discovery requests.

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 other than prosecuting this litigation is warranted. The parties hereto desire a protective order to protect the interests of each, respectively, in their own confidential information, as defined in Paragraph 3.1, by controlling access to and use of such information, while allowing discovery of the same to conduct this litigation and not for any other purpose.

The parties acknowledge that this Order does not confer blanket protections on all disclosures or responses to discovery and that the protection it affords extends only to the limited information or items entitled under the applicable legal principles to treatment as protected material, as defined below.

2. GOOD CAUSE FOR ENTRY

There is good cause for this Order in this action because discovery and disclosure will necessarily entail, among other things: (1) confidential and protected information regarding customers of Defendants, and (2) information from Defendants regarding their business, business operations, proprietary computer and data systems which are competitively sensitive and confidential.

3. DEFINITIONS

3.1 Confidential Information

Information or tangible things, regardless of how generated, stored, or maintained, designated as "Confidential," such as trade secret information and confidential, competitive, or proprietary information, which qualify for protection under the standards developed under Federal Rule of Civil Procedure 26(c) and are designated as provided below in Paragraphs 5.2, 5.3, 5.4, and 5.5.

This includes information such as customer or account information that identifies a customer or contains any protected information (such personal information provided for the purposes of evaluating prospective tenants and rental payments); sensitive business documents that disclose the company's competitive strategies or inner workings; and non-public financial information.

3.2 Counsel

Attorneys of record for the parties in this action, including their regular and temporary employees, such as paralegal, stenographic, and clerical employees.

3.3 Designating Party

A party or non-party that designates information or items that it produces in disclosures or responses to discovery as "Confidential."

3.4 Expert

A person with specialized knowledge or experience in a matter pertinent to this litigation who has been retained by a party or its counsel to serve as an expert witness or as a consultant in this action and who is not a current employee of a party or of a competitor of a party (where competitors are limited to those entities whose primary business consists of the rental or sale of real estate) and who, at the time of retention, is not anticipated to become an employee of a party or a competitor of a party. This definition includes support staff employed by any such person, as well as any professional jury or trial consultants retained in connection with this litigation.

3.5 Party

Any party to this action, including all of its officers, directors, agents, representatives, or other employees, and those of its parent or affiliated ...


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