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Evan Hightower and Ann Ross, Individually, and On Behalf of All Other v. Jpmorgan Chase Bank

August 8, 2012

EVAN HIGHTOWER AND ANN ROSS, INDIVIDUALLY, AND ON BEHALF OF ALL OTHER SIMILARLY SITUATED, PLAINTIFFS,
v.
JPMORGAN CHASE BANK, N.A.; AND DOES 1 - 10, INCLUSIVE, DEFENDANTS. CAROLYN SALAZAR, ROGER ALCHAIKH, AND ESTELLA SLIKKER, INDIVIDUALLY, AND ON BEHALF OF ALL OTHER MEMBERS OF THE GENERAL PUBLIC SIMILARLY SITUATED, PLAINTIFFS, V. JPMORGAN CHASE BANK, N.A.; AND DOES 1 THROUGH 10, INCLUSIVE, DEFENDANT. REGINA M. SIMPSON AND REGINA STURDIVANT, INDIVIDUALLY, ON BEHALF OF THEMSELVES, ALL OTHER SIMILARLY SITUATED, AND ON BEHALF OF THE GENERAL PUBLIC; PLAINTIFFS,
v.
JPMORGAN CHASE BANK, A NEW YORK CORPORATION; JPMORGAN CHASE & CO., A DELAWARE CORPORATION; CHASE HOME FINANCE LLC, A DELAWARE LIMITED LIABILITY COMPANY; AND DOES 1 TO 10, INCLUSIVE, DEFENDANTS. DENNIS KHUTORETSKY, MIKHAIL LIRMAN, AND BORIS SHULMAN, ON BEHALF OF THEMSELVES AND ALL OTHER SIMILARLY SITUATED, PLAINTIFFS,
v.
J.P. MORGAN CHASE & CO., AND J.P. MORGAN CHASE BANK, N.A., DEFENDANTS.



The opinion of the court was delivered by: Honoorable Paul L. Abram United Magistrate Judge

#:1018

DEFINITIONS

1. For the purpose of this Order:

(a) "Information" is defined broadly to include information in any form, whether provided in response to a request for information, in documents, or in testimony;

(b) "Document" is defined broadly to include tangible paper as well as information stored electronically on disc, tape or otherwise;

(c) "Confidential Material" is defined to include information designated as "Confidential" or "Highly Confidential -- Attorneys' Eyes Only" or provisionally treated as "Confidential" or "Highly Confidential -- Attorneys' Eyes Only" under the terms of this Order.

SCOPE, DESIGNATION AND USE OF CONFIDENTIAL MATERIAL

2. The parties acknowledge that they will be requesting and exchanging documents and information solely because they are parties to the Litigation and therefore agree that all material exchanged between them will be used only for purposes of and in connection with prosecuting or defending this Litigation, actions that have been related to this Litigation, and/or alternative dispute resolution efforts between the parties hereto and for no other purpose. In addition, the parties acknowledge that certain of the documents and materials exchanged in discovery in this Litigation will be sensitive and confidential and deserve additional protections from disclosure, as set forth in this Order. Counsel for each party, and each person receiving Confidential Material must take reasonable precautions to prevent the unauthorized or inadvertent disclosure of such information.

3. A party or non-party subject to discovery in the Litigation may designate as "Confidential" or "Highly Confidential -- Attorneys' Eyes Only" documents or information produced in discovery that the party or non-party considers in good faith to contain confidential information, including but not limited to information falling within the following categories: (a) Confidential Information. "CONFIDENTIAL INFORMATION" is defined herein as: (i) a trade secret or other confidential research, development or commercial information; and/or (ii) any sensitive personal information of nonparties, the parties, or their managers, representatives or employees, current or former, including the following: Social Security number, date of birth, medical records, medical information, personnel records, address(es), telephone records/numbers, e-mail address(es), wage and benefit data, account numbers, tax records, and other financial information such as credits, loans, or other business transactions, assets, and/or income data; (b) Attorneys' Eyes Only Information. "ATTORNEYS' EYES ONLY INFORMATION" is defined herein as CONFIDENTIAL INFORMATION which constitutes, discloses, reveals, describes or discusses, in whole or in part, a trade secret within the meaning of the California Uniform Trade Secrets Act, financial statements or budgets of Defendant, provided however, to the extent that any party intends to rely on that party's budgets, financial statements or net worth information in support of, or in defense against, a claim for damages or for recovery of equitable relief of a monetary nature, such information shall be designated as Confidential, and not Attorneys' Eyes Only.

4. A party or non-party seeking to designate as "Confidential" or "Highly Confidential -- Attorneys' Eyes Only" any document that that party or non-party produces in response to a document request or subpoena in the Litigation shall designate the document as confidential by labeling the document "Confidential" or "Highly Confidential -- Attorneys' Eyes Only" on the face of each page of the document, along with an indication identifying the producing party. In the event a producing party elects to produce materials for inspection, no marking need be made by the producing party in advance of the initial inspection. For purposes of the initial inspection, all materials produced will be considered as "Highly Confidential -- Attorneys' Eyes Only" and must be treated as such pursuant to the terms of this Order. Thereafter, upon selection of specified materials for copying by the inspecting party, the producing party must, within a reasonable time prior to producing those materials to the inspecting party, mark the copies of those materials that contain Confidential Information with the appropriate confidentiality marking.

5. If a party believes that a document produced by someone other than that party contains confidential information, the party wishing to designate such confidential information under the terms of this Order shall notify the other party in the Litigation in writing that it considers the information confidential, label the affected document with the legend "Confidential" or "Highly Confidential -- Attorneys' Eyes Only" on the face of each page of the document along with an indication identifying the party designating the document as confidential, and send a copy of the document with the appropriate "Confidential" or "Highly Confidential

-- Attorneys' Eyes Only" legend to the non-designating party. 6. A party or non-party seeking to designate as "Confidential" or "Highly Confidential -- Attorneys' Eyes Only" any written response to an interrogatory or other request provided by that party or non-party shall designate the response as confidential by clearly indicating the page(s) or section(s) of the response that is designated as confidential, including by placing the legend "Confidential" or "Highly Confidential -- Attorneys' Eyes Only" on the face of each page of the response that contains confidential information. If a party believes that a written discovery response served by someone other than the party seeking to designate the response or any portion thereto as confidential, the designating party shall designate the response as confidential by clearly indicating the page(s) or section(s) of the response that is designated as confidential, including by placing the legend "Confidential" or "Highly Confidential -- Attorneys' Eyes Only" on the face of each page of the response that contains confidential information, and shall send a copy of the document with the appropriate confidentiality legend to the non-designating party.

7. A party also may designate as "Confidential" or "Highly Confidential

-- Attorneys' Eyes Only" any deposition testimony by (a) stating orally on the record of a deposition that the entire transcript or portion thereof is "Confidential" or "Highly Confidential -- Attorneys' Eyes Only"; or (b) by written notice to counsel for the other party in the Litigation of such ...


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