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Michael Chow, Known As "Mr Chow," Mr Chow Enterprises, Ltd., A v. Giuseppe Cipriani

November 9, 2011

MICHAEL CHOW, KNOWN AS "MR CHOW," MR CHOW ENTERPRISES, LTD., A CALIFORNIA LIMITED PARTNERSHIP, MC MIAMI ENTERPRISES, LLC, A FLORIDA LIMITED LIABILITY COMPANY, MC TRIBECA, LLC, A NEW YORK LIMITED LIABILITY COMPANY, AND TC VENTURES, INC., A NEW YORK CORPORATION, PLAINTIFFS,
v.
GIUSEPPE CIPRIANI, IGNAZIO CIPRIANI, MAGGIO CIPRIANI AND DOES 1 THROUGH 10, DEFENDANTS.



The opinion of the court was delivered by: Honorable Ralph Zarefsky U.S. Magistrate Judge

KATTEN MUCHIN ROSENMAN LLP Alan R. Friedman (SBN 241904) alan.friedman@kattenlaw.com Gail Migdal Title (SBN 49023) gail.title@kattenlaw.com Kristin L. Holland (SBN 187314) kristin.holland@kattenlaw.com Tami Kameda Sims (SBN 245628) tami.sims@kattenlaw.com 2029 Century Park East, Suite 2600 Los Angeles, CA 90067-3012 Telephone: 310.788.4400 Facsimile: 310.788.4471 Attorneys for Defendants Giuseppe Cipriani, Ignazio Cipriani, Maggio Cipriani, Mr. C. Manager, LLC, and Mr. C-USA, LLC

Hon. A. Howard Matz

STIPULATED PROTECTIVE ORDER

NOTE: CHANGES HAVE BEEN MADE TO THIS DOCUMENT

WHEREAS, the parties to this action having agreed, through their respective counsel, to the entry of the following Protective Order ("Protective Order") pursuant to Rule 26(c) of the Federal Rule of Civil Procedure,

NOW THEREFORE, IT IS HEREBY ORDERED that:

1. Purpose of the Protective Order and Definition of Materials Subject To the Protective Order.

Plaintiffs Michael Chow, MC Miami Enterprises, LLC, MC Tribeca, LLC, and TC Ventures, Inc. (collectively, "Plaintiffs") are engaged in the restaurant business and related businesses. Defendants Giuseppe Cipriani, Ignazio Cipriani, Maggio Cipriani, Mr. C. Manager, LLC, and Mr. C-USA, LLC (collectively "Defendants") are engaged in the hospitality business and restaurant business and/or provide services to companies engaged in the hospitality business and restaurant business. Through the course of this action, Plaintiffs and Defendants (a "Party" or the "Parties") have sought discovery and/or anticipate seeking discovery relating to the following "SENSITIVE BUSINESS INFORMATION" pertaining to the Parties' respective businesses, i.e.,:

(a) information on revenue, profit or costs;

(b) financial projections, evaluations, or forecasts of revenue, profit or costs;

(c) business plans;

(d) market research or surveys;

(e) business models.

Due to its confidential and proprietary nature, SENSITIVE BUSINESS INFORMATION concerning a Party, if made public, would greatly prejudice such Party because its competitors would be able to utilize the SENSITIVE BUSINESS INFORMATION to gain an unfair business advantage.

Accordingly, good cause exists to allow the Parties, or any nonparty from whom discovery is sought, to designate materials, documents, things, or other information or evidence whose discovery is contemplated under Rules 26-37, and 45 of the Federal Rules of Civil Procedure, including without limitation, deposition testimony, answers to requests for admissions, answers to interrogatories, and documents or things which contain, include, constitute, or refer to, the SENSITIVE BUSINESS INFORMATION as "CONFIDENTIAL" (hereinafter "CONFIDENTIAL Materials").

2. Scope Of The Protective Order.

Anything that is designated CONFIDENTIAL shall be deemed subject to the provisions of this Protective Order. Further, copies of CONFIDENTIAL Materials and any receiving Party's summary, compilation, or expression in another medium of all or a portion of these materials are protected under this Protective Order to the same extent as the original CONFIDENTIAL Materials. No Party or nonparty shall designate material as "CONFIDENTIAL" unless counsel for the designating Party or nonparty believes in good faith that the designated material is entitled to protection under Federal Rule of Civil Procedure 26(c)(7) and by the terms of this Protective Order and that the designated material is not already available to the general public.

3. Designation Of Material Subject To The Protective Order.

Whenever a Party or nonparty herein determines that a document, thing, or other information (except for deposition testimony) constitutes CONFIDENTIAL Materials, such must be designated prior to its release to the receiving Party as "CONFIDENTIAL." The protocol for designating ...


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