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Raquel Rubio, On Behalf of Herself and All Others Similarly Situated v. Capital One Bank (Usa)

January 23, 2012

RAQUEL RUBIO, ON BEHALF OF HERSELF AND ALL OTHERS SIMILARLY SITUATED, PLAINTIFF,
v.
CAPITAL ONE BANK (USA), N.A. AND DOE DEFENDANTS 1-10, ET AL., DEFENDANT.



The opinion of the court was delivered by: Hon. Carla Woehrle

[PROPOSED] ORDER GOVERNING THE DESIGNATION AND HANDLING OF CONFIDENTIAL DOCUMENTS AND INFORMATION

Action Filed: October 18, 2007 Discovery Cut-Off: Pretrial Conference: Trial Date:

[PROPOSED] ORDER

Based on the Stipulation Governing the Designation and Handling of Confidential Documents and Information filed by the parties, a copy of which is attached to this Order ("Stipulation"), and good cause appearing therefore,

IT IS HEREBY ORDERED that the Stipulation is approved and entered as an Order of the Court and that the terms of the Stipulation shall have the force and effect of an Order of the Court.

IT IS SO ORDERED.

By ____________/s/______________

Honorable Carla Woehrle

Exhibit A

JAMES F. McCABE (CA SBN 104686) JMcCabe@mofo.com MORRISON & FOERSTER LLP 425 Market Street San Francisco, California 94105-2482 Telephone: 415.268.7000 Facsimile: 415.268.7522 NANCY R. THOMAS (CA SBN 236185) NThomas@mofo.com SYLVIA RIVERA (CA SBN 223203) SRivera@mofo.com MORRISON & FOERSTER LLP 555 West Fifth Street Los Angeles, California 90013-1024 Telephone: 213.892.5200 Facsimile: 213.892.5454 Attorneys for Defendant CAPITAL ONE BANK (USA), N.A.

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA

RAQUEL RUBIO, on behalf of herself and all others similarly situated, Plaintiff, v. CAPITAL ONE BANK (USA), N.A. and DOE DEFENDANTS 1-10, et al., Defendant.

Case No. CV 07-06766 ABC (CWx) Hon. Carla Woehrle Action Filed: October 18, 2007 Discovery Cut-Off: Pretrial Conference: Trial Date:

STIPULATION GOVERNING THE DESIGNATION AND HANDLING OF CONFIDENTIAL DOCUMENTS AND INFORMATION

I.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 any purpose other than prosecuting or defending this litigation would be warranted. Accordingly, the parties hereby stipulate to the following Stipulation Governing the Designation and Handling of Confidential Documents and Information and request that the Court enter this Stipulation as an Order of the Court ("Stipulated Protective Order").

The parties acknowledge that this Stipulated Protective 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 that are entitled under the applicable legal principles to treatment as confidential. The parties further acknowledge that this Stipulated Protective Order creates no entitlement to file confidential information under seal; Central District Local Rule 79-5 sets forth the procedures that must be followed and reflects the standards that will be applied when a Party seeks permission from the Court to file material under seal.

II.DEFINITIONS

1. "Material" means any document, data compilation, transcript, or other information in any form provided in connection with this case.

2. "Confidential Material" means Material that is designated as "Confidential" or "Confidential -- Subject to Protective Order" in accordance with this order and protected from disclosure under the terms of this order. Confidential Material is material that a party reasonably and in good faith believes contains or discloses confidential, non-public, proprietary, and/or sensitive information such as customer financial information and data, proprietary, competitively-sensitive nonpublic commercial information such as business policies, strategic planning, and competitive analyses, and other competitively sensitive information that is of a nonpublic nature that was created, received and/or maintained on a confidential basis. Confidential Material includes: a) personal and financial information of Plaintiff or any other individual; b) sensitive customer information such as mailing addresses, account numbers, and account information; c) non-public revenue, cost, sales and financial information, and projections; d) non-public marketing plans; e) pricing information; and f) any other information the Producing Party can demonstrate is sufficiently sensitive that disclosure would reveal business, competitive, proprietary, or financial information of the Producing Party.

3. "Party" or "Parties" means the named parties in this lawsuit.

4. "Producing Party" means a person who produces Material in ...


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