The opinion of the court was delivered by: Hon. Robert N. Block United States Magistrate Judge
CHARLES E. PATTERSON (CA SBN 120081) SHELLA L. SADOVNIK (CA SBN 267551) BENJAMIN J. FOX (CA SBN 193374) MORRISON & FOERSTER LLP 555 West Fifth Street Los Angeles, California 90013-1024 Telephone: 213.892.5200 Facsimile: 213.892.5454 CPatterson@mofo.com; BFox@mofo.com SSadovnik@mofo.com Attorneys for Defendants and Counterclaimants TULAMMO USA, INC. and EUROSPORTS, LLC and Defendant CHARLES E. GRASSO
STIPULATION AND [PROPOSED] SUPPLEMENTAL PROTECTIVE ORDER
Magistrate Judge Robert N. Block Discovery Cutoff: February 6, 2012 Pretrial Conference: August 6, 2012 Trial Date: September 14, 2012
The parties hereby stipulate and agree pursuant to Rule 26(c) of the Federal Rules of Civil Procedure, that this Supplemental Protective Order shall govern the production and/or disclosure by any party or non-party (the "Producing Party") in this action, including, without limitation, Rule 26 disclosures, documents, depositions, deposition exhibits, interrogatory responses, responses to requests for admission, and testimony (such information shall hereinafter be referred to as "Discovery Material") and the handling of all such information produced or disclosed to any party (the "Receiving Party").
1. This Supplemental Protective Order incorporates by reference all of the terms and conditions of the Protective Order dated May 5, 2011 (Dkt. 51) and does not alter any such terms and conditions except to the extent expressly stated herein.
2. "Export Controlled Information" shall mean Discovery Material that is subject to the requirements of the Export Administration Regulations ("EAR"), 15 C.F.R. § 730 et seq., and/or the International Traffic in Arms Regulations ("ITAR"), 22 C.F.R. § 120 et seq. Such Discovery Material may be dual use commodities, technology, software, or defense articles.
3. A party producing Discovery Material it believes includes Export Controlled Information shall produce copies bearing a legend that includes the following text: "EXPORT CONTROLLED INFORMATION."
4. No party shall transport or cause to be transported Discovery Material marked as EXPORT CONTROLLED INFORMATION outside of United States territory. Moreover, a party shall disclose such Discovery Material only to U.S. Persons as defined by 22 C.F.R. § 120.15, and shall not otherwise export such Discovery Material in violation of EAR or ITAR. The text of 22 C.F.R. §§ 120.15 and 120.16 are attached hereto as Exhibit B.
4. Before disclosing or transferring any Discovery Material marked as EXPORT CONTROLLED INFORMATION to any person, counsel for the receiving party shall obtain from such person an undertaking in the form attached hereto as Exhibit A. Counsel for the receiving party shall maintain all such executed undertakings until two years after either a final, non-appealable order dismissing all claims and counterclaims in this action, or after the receiving party destroys, and certifies to the destruction of, all confidential information it has received from the disclosing party. Counsel for the receiving party shall make available copies of such executed undertakings if so requested by the producing party and if good cause exists for such a request.
Case No. SACV10-1338 AG (RNBx)
UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA SPORTING SUPPLIES INTERNATIONAL, INC., a California corporation, Plaintiff, v. TULAMMO USA, INC., a Texas Corporation, CHARLES GRASSO, an individual, TULA CARTRIDGE WORKS, an open joint-stock company, ULYANOVSK CARTRIDGE WORKS, an open joint-stock company, EUROSPORTS, LLC, a limited liability company, and DOES 1 through 10, inclusive, Defendants. TULAMMO USA, INC., a Texas Corporation and EUROSPORTS, LLC, a limited liability ...