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Cynthia M. Piasecki v. Lozano Smith

February 16, 2012

CYNTHIA M. PIASECKI,
PLAINTIFF,
v.
LOZANO SMITH, INC., CARLITA ROMERO, AND DOES 1-10.,
DEFENDANT.



The opinion of the court was delivered by: Sandra M. Snyder United States Magistrate Judge

STIPULATED PROTECTIVE ORDER Trial Date: April 8, 2013

Documents and information subject to discovery in this action reflect, or may reflect, confidential financial, commercial, proprietary, medical, personnel or personal information of the parties and non-parties. The following Stipulation and Protective Order shall govern the production, disclosure, and use of such confidential information in this action.

STIPULATION RE PROTECTIVE ORDER

IT IS HEREBY STIPULATED AND AGREED, by and between the parties, through their respective undersigned counsel, that a Protective Order shall be entered in this action as follows:

1.Definition of Confidential Information.

For purposes of this Stipulation and Protective Order, "confidential information" means the originals or copies of business or financial records, documents containing trade secrets or proprietary information, personnel records, medical records and any other writing as defined by Federal Rule of Civil Procedure 34(a)(a)(A) reflecting confidential, commercial, medical or personal information that counsel for any of the stipulating parties has in good faith designated as confidential, and also included in the definition of "confidential information" is the information on said records or documents or other information that counsel for any of the stipulating parties has in good faith designated as confidential. No information shall be claimed to be confidential unless counsel making the claim has a reasonable, good faith belief that the information meets the criteria specified above. Once so designated, confidential documents, records or information shall be subject to the protection of this Protective Order unless such protection is expressly waived in writing by all of the stipulating parties or to the extent the Court rules that information, a document and/or a record shall not be subject to this Protective Order. Receipt of the same or similar information from a separate or different source or document does not remove the information, document(s) and/or record(s) designated as confidential from the protection of this Protective Order.

2.Time and Manner of Designation.

Counsel may designate documents, writings and/or information as confidential at the time of the production of the information, documents or other writings which counsel believes in good faith is confidential. Documents produced prior to the execution of this Stipulation for Protective Order and Protective Order may be designated confidential by the producing party so long as counsel so designating has a reasonable, good faith belief that the information meets the criteria specified above.

Documents shall be designated confidential by placing the word "confidential" in red (if readily available) on the document or, if the document was produced prior to the execution of this Stipulation for Protective Order and Protective Order, by identifying the document as confidential in writing to all counsel. Information given in deposition shall be designated confidential on the record during the deposition. Confidential information given during a deposition can be designated confidential at any time during the deposition or within the time period allowed for making corrections to the deposition. If requested by counsel, such information will be transcribed by the Court Reporter in a separate "confidential booklet" clearly marked "Confidential" on the outside front cover.

3.Coverage.

This Protective Order shall control production, disclosure, and use of confidential information throughout the course of this case. This Protective Order shall not constitute or be deemed to constitute any admission by any of the stipulating parties or a determination by the Court as to any contested issue in this case, including, without limitation, the existence or nonexistence of a privacy interest or privilege relating to said confidential information or its admissibility at trial.

4.Limits on Disclosure and Use.

Documents and information obtained in discovery and designated confidential pursuant to this Stipulation shall not be disclosed to any person including any competitors or any other person except that documents and information designated confidential may be disclosed to the following persons and entities, provided that to do so is necessary ...


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