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Abarca, Raul Valencia, et al v. Merck & Co.

April 26, 2012

ABARCA, RAUL VALENCIA, ET AL., PLAINTIFFS,
v.
MERCK & CO., INC., ET AL.,
DEFENDANTS.



The opinion of the court was delivered by: David O. Carter Judge of the U.S. District Court Central District of California

JOHN F. BARG (SBN 60230; jfb@bcltlaw.com) STEPHEN C. LEWIS (SBN 66590; scl@bcltlaw.com) R. MORGAN GILHULY (SBN 133659; rmg@bcltlaw.com) BARG COFFIN LEWIS & TRAPP, LLP 350 California St., 22nd Floor San Francisco, California 94104-1435 Telephone: (415) 228-5400 Fax: (415) 228-5450 Attorneys for Defendants Merck & Co., Inc., Amsted Industries Incorporated, and Baltimore Aircoil Company, Inc.

STIPULATION; RECOMMENDATION OF SPECIAL MASTER; AND ORDER FOR ENTRY OF PROTECTIVE ORDER RE: CONFIDENTIAL DOCUMENTS, U.S.D.C. Case No. Civ. 1:07-cv-00388-DOC-DLB

WHEREAS, defendants Merck and Co., Inc. ("Merck"), Amsted Industries Incorporated ("Amsted"), and Baltimore Aircoil Company, Inc. ("BAC") (collectively, "Defendants") may be required to produce in discovery in this action 3 documents, information, and/or tangible objects that contain sensitive, confidential, 4 and proprietary business information ("Confidential Documents").

GOOD CAUSE STATEMENT

WHEREAS, good cause exists for the Court to enter this Protective Order, as 7 it is necessary to protect the Confidential Documents of Defendants.

WHEREAS, the Court's entry of this Protective Order will ensure that the 9 Confidential Documents will not be publicly disseminated or revealed in a manner 10 that would compromise or injure Defendants' business interests.

WHEREAS, in order to facilitate discovery and preserve the confidentiality 12 of the Confidential Documents, plaintiffs and Defendants (collectively, "the 13 Parties") stipulate to and request that the Court enter the following Protective Order 14 governing the production, disclosure, and use of the Confidential Documents.

STIPULATION

IT IS HEREBY STIPULATED by and between plaintiffs and Defendants, through their respective attorneys as follows:

1. The producing party shall stamp, watermark, or otherwise mark each

Confidential Document with the following phrase ("Confidentiality Stamp"):

CONFIDENTIAL:

This document is subject to the

[date] Protective Order entered by the United States District Court for the Eastern District of California in Abarca, et al. v. Merck & Co., Inc., et al. (Case No. 1:07-CV-0388-DOC-DLB)

2. No Party shall disclose any Confidential Document bearing a

Confidentiality Stamp as set forth in Paragraph 1, any portion of any such Confidential Document, or the subject matter or contents of any such Confidential

Document which is not already contained in any document not subject to this Protective Order, to any person or entity, except as set forth herein.

The Parties receiving Confidential Documents in discovery in this action are the temporary custodians of the Confidential Documents. All Confidential Documents shall be 4 used by the Parties to whom such information is disclosed solely for the 5 prosecution, defense, or settlement of this action and shall not be used for any other 6 purpose including, but not limited to, any other ...


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