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T-Mobile West Corporation, A Delaware Corporation v. City of Huntington Beach

January 27, 2012

T-MOBILE WEST CORPORATION, A DELAWARE CORPORATION, PLAINTIFF,
v.
CITY OF HUNTINGTON BEACH, A PUBLIC ENTITY ORGANIZED AND EXISTING UNDER THE LAWS OF THE STATE OF CALIFORNIA; CITY COUNCIL OF THE CITY OF HUNTINGTON BEACH, DEFENDANTS.



The opinion of the court was delivered by: The Honorable Suzanne H. Segal United States Magistrate Judge

[Discovery Document: Referred to Magistrate Judge Suzanne H. Segal]

[PROPOSED] PROTECTIVE ORDER

Second Amended Complaint filed January 18, 2011

Having reviewed the Stipulation Regarding Protective Order between the City of Huntington Beach (the "City" or "Defendant") and T-Mobile West Corporation ("T-Mobile" or "Plaintiff"), and good cause appearing, IT IS HEREBY ORDERED as follows:

This proposed protective order (the "Protective Order") shall govern the production or disclosure of any record or information designated as "Confidential Information" and produced by the Parties or their agents during the course of discovery, pretrial proceedings, or trial in this suit, including all designated deposition testimony, all designated testimony taken at a hearing or other proceeding, interrogatory answers, documents and other discovery materials, whether produced informally, in response to interrogatories, requests for admissions, requests for production of documents, or any other formal method of discovery. In addition, the Parties contemplate that Confidential Information may be produced by a non-party. This Protective Order also shall govern any designated record or information produced in this action pursuant to disclosures required under any applicable Federal Rule of Civil Procedure or Central District of California Local Rule and any supplementary disclosures thereto.

1. DESIGNATION

The City has sought production of documents regarding the performance and coverage of T-Mobile's wireless telecommunications system, including the following categories of materials:

(1) T-Mobile's Daily Reports on Dropped Calls, Blocked Calls and System Accessibility for the area of the City of Huntington.

(2) The Antenna and Sector Site Maps for the City of Huntington Beach.

(3) The number of T-Mobile subscribers within the City of Huntington Beach.

(4) The "Drive Tests" and related system performance reports prepared by T-Mobile's consultants.

(5) Documents regarding the "propagation models" and drive tests T-Mobile employs for predicting system performance.

(6) "Radio Frequency Design Guidelines" and similar reports issued by the Field Service Center of T-Mobile.

(7) Reports regarding potential antenna locations serving the City of Huntington Beach.

(8) Documents containing "trade secrets, confidential research, development, or commercial information" within the meaning of Rule 26(c), which pertain to T-Mobile's decision-making with respect to its wireless facilities and coverage area.

(9) Financial and technological methodologies for evaluating and selecting sites.

Plaintiff may designate as "CONFIDENTIAL" any discovery within the above categories. Any Confidential Information shall be clearly marked "CONFIDENTIAL" prior to production, or subsequent to selection for copying (i.e., in cases where Confidential Information is made ...


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