Assigned to: Honorable Ronald S. W. Lew
First Amended Complaint Filed: 6-3-11
PROPOSED ORDER RE: STIPULATED PROTECTIVE ORDER
Note changes made by court
Subject to the approval of this Court, the parties DISNEY ENTERPRISES, INC., and UNITED LOGISTICS, INC., (hereinafter "the parties") hereby stipulate to the following protective order:
1. In connection with discovery proceedings in this action, United Logistics, Inc. may designate any document, thing, material, testimony or other information derived therefrom, as "Confidential" under the terms of this Stipulated Protective Order (hereinafter "Order"). Confidential information is information which has not been made public and which concerns or relates to the amount or source of any income, profits, losses, or expenditures or the tax returns of United Logistics, Inc.
By designating a document, thing, material, testimony or other information derived therefrom as "Confidential," under the terms of this order, United Logistics, Inc. is certifying to the court that there is a good faith basis both in law and in fact for the designation with the meaning of Federal Rule of Civil Procedure 26(g).
2. Confidential documents shall be so designated by stamping copies of the document produced to a party with the legend "CONFIDENTIAL." Stamping the legend "CONFIDENTIAL" on the cover of any multipage document shall designate all pages of the document as confidential, unless otherwise indicated by the producing party.
3. Testimony taken at a deposition, conference, hearing or trial may be designated as confidential by making a statement to that effect on the record at the deposition or other proceeding. Arrangements shall be made with the court reporter taking and transcribing such proceeding to separately bind such portions of the transcript containing information designated as confidential, and to label such portions appropriately.
4. Material designated as confidential under this Order, the information contained therein, and any summaries, copies, abstracts, or other documents derived in whole or in part from material designated as confidential (hereinafter "Confidential Material") shall be used only for the purpose of the prosecution, defense, or settlement of this action, and for no other purpose.
5. Confidential Material produced pursuant to this Order may be disclosed or made available only to the Court, to counsel for Disney Enterprises, Inc. (including the paralegal, clerical, and secretarial staff employed by such counsel), and to the "qualified persons" designated below:
(a) an officer, director, or employee of Disney Enterprises, Inc. deemed necessary by counsel to aid in the prosecution, defense, or settlement of this action;
(b) experts or consultants (together with their clerical staff) retained by such counsel to assist in the prosecution, ...