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Fedex Ground Package System, Inc., A Delaware Corporation v. Blackhawk Manufacturing

May 23, 2012

FEDEX GROUND PACKAGE SYSTEM, INC., A DELAWARE CORPORATION, PLAINTIFF,
v.
BLACKHAWK MANUFACTURING, INC., A CALIFORNIA CORPORATION,, DEFENDANT.



The opinion of the court was delivered by: Magistrate Judge: Hon. Oswald Parada

STIPULATED PROTECTIVE ORDER DISCOVERY MATTER Crtrm: 11

Judge: Hon. Otis D. Wright II

The following Protective Order is hereby stipulated to by and between Plaintiff FedEx Ground Package System, Inc. ("FedEx Ground") and Defendant Blackhawk Manufacturing, Inc. ("Blackhawk").

WHEREAS, the parties anticipate that discovery in the above-entitled action will encompass sensitive, confidential or proprietary information and documents that are sensitive, confidential or proprietary in nature;

WHEREAS, in the absence of a protective order, the parties' sensitive, confidential or proprietary information may be subject to disclosure in this litigation to the parties' detriment;

WHEREAS, the parties' exchange of documents and information will be facilitated by the Court entering this Protective Order;

NOW, THEREFORE, IT IS HEREBY ORDERED THAT:

1. This Protective Order shall govern all documents, discovery materials, or any designated record of information produced in this action, 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 or in response to interrogatories, requests for admissions, requests for production of documents, or other formal method of discovery) produced within the context of this action.

2. Either party hereto may designate information as "CONFIDENTIAL," pursuant to the terms of this Protective Order, if that party in good faith believes that such information constitutes, contains or reflects proprietary or commercially sensitive information. All information, including without limitation all copies, excerpts, analyses, reports, notes or summaries based upon or derived from any information that has been designated as CONFIDENTIAL, shall be considered to be CONFIDENTIAL.

3. CONFIDENTIAL information or items shall mean any information that the designating party in good faith believes is properly protected under Fed. R. Civ. P. 26(c), and which is properly designated as "CONFIDENTIAL" according to the procedures set forth in Paragraph 5 of this Protective Order.

4. Documents and information designated as CONFIDENTIAL shall include: (a) all copies, extracts, and complete or partial summaries prepared from such documents or information; (b) portions of deposition transcripts and exhibits that contain or reflect the content of any such documents, copies, extracts, or summaries; (c) portions of briefs, memoranda, or any other writing filed with the Court and exhibits that contain or reflect the content of any such documents, copies, extracts, or summaries, and (d) deposition testimony.

5. After the date of this Protective Order, to designate any information or documents as CONFIDENTIAL, such that the information or documents are protected under this Protective Order, either party shall:

(a) In the case of documents, mark such document, or portions of such document, "CONFIDENTIAL" at or prior to the time it is produced or otherwise made available by one party hereto to the other party hereto, or as soon as is practicable thereafter.

(b) In the case of responses to particular interrogatories, requests for admissions or requests for production of documents made after the date of this Protective Order, any CONFIDENTIAL material in such responses shall be set forth in a separate document containing a statement to the effect that "THIS RESPONSE CONTAINS CONFIDENTIAL MATERIAL," and the legend "CONFIDENTIAL, SUBJECT TO COURT ORDER," shall be placed on each page of any such set of responses. CONFIDENTIAL portions of such responses made prior to the date of this Protective Order may be designated as CONFIDENTIAL.

6. All information, including without limitation all documents, designated as CONFIDENTIAL shall be used solely in this action, and not be disclosed in any manner to anyone other than the following:

(a) counsel (including in-house counsel) who are actively engaged in the prosecution or defense of this action; the employees or agents of such counsel assisting in the conduct of this action; the parties to the action; and, where necessary, partners, employees, or agents of parties to the action;

(b) bona fide experts assisting counsel in the prosecution or defense of this action, whether categorized as "testifying" or "consulting," whom the attorneys represent have been specifically instructed not to discuss or disclose information that has been designated CONFIDENTIAL other than with counsel of record;

(c) witnesses and their counsel in this action where deemed necessary by counsel to assist in the ...


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