The opinion of the court was delivered by: Honorable James Ware United States District Judge
Mark C. Gabel (CA State Bar No. 253729) I 2 Stuart Miller ( CA S tate Bar No. 127766) DAVIS WRIGHT TREMAINE LLP U A 505 Montgomery Street, Suite 800 I 3 San Francisco, CA 94111-6533 N James Ware R Telephone: (415) 276-6500 O Judge O Facsimile: (415) 276-6599 R F Email: email@example.com H L firstname.lastname@example.org E Kenneth D. Kleinman (PA State Bar No. 31770) (Pro Hac Vice) 7 Joseph D. Shelby (PA State Bar No. 69399) (Pro Hac Vice pending) 8 STEVENS & LEE, P.C. 1818 Market Street, 29th Floor 9 Philadelphia, PA 19103-1702 Telephone: (215) 575-0100 10 Facsimile: (215) 851-0214 Email: email@example.com 11 firstname.lastname@example.org Attorneys for DEFENDANT HEALTHCARE SERVICES GROUP, INC. 13 14
[PROPOSED] STIPULATED PROTECTIVE ORDER State Court Action Filed: September 30, 2011
Subject to the approval of this Court, Plaintiff TONY M. GLENN ("Glenn" or "Plaintiff") 25 and Defendant HEALTHCARE SERVICES GROUP, INC. ("HSG" or "Defendant"), by and 26 through their respective counsel of record, stipulate to the following Protective Order. This 27 Protective Order is intended to account for and protect any and all financial, proprietary, and trade 28 secret information, as well as any private personal information of any of the parties, or of any third party, that is produced in this case.
The parties, or any of them, may determine that certain information is
confidential and that
4 they do not want to disclose that information in this litigation
without an obligation of secrecy. The 5 parties therefore agree as
follows regarding their obligations of secrecy with respect to such 6
information disclosed during discovery. 7
circumstances of this case, Orders as follows: 9
a. "Party" or "Parties" means any party in the above captioned lawsuit. "Third Party" or "Third Parties" means every natural person or entity other than the Parties and their counsel.
b. "Documents" means all documents, transcribed deposition testimony, and other products of discovery; all information derived directly or indirectly therefrom (excluding the work product of counsel), produced, made available, or given by any party hereto, subsequent to the date of this Stipulation, whether produced voluntarily or pursuant to a subpoena or court order; and all copies, excerpts or summaries thereof. "Documents" includes, but is not limited to, documents produced or made available pursuant to the Federal Rules of Civil Procedure, and responses to requests for production of documents, requests for admission, or interrogatories.
c. "Confidential Information" means any information which is disclosed in discovery or in some other proceeding in this litigation, and which is designated as Confidential Information in good faith prior to or at the time of its disclosure by the party asserting confidentiality, whether such designation be oral at a hearing or deposition, or in writing, and whether such disclosure is voluntary or not. Only material that falls into one of the following six categories may be designated as Confidential Information:
The Court, finding that the agreement of the parties is proper and desirable in the
1. The following definitions apply to this Order:
i. Personal information, including addresses, phone numbers, email addresses, and other contact information, of any officer, employee, or former employee of Defendant other than Plaintiff.
ii. Employment or personnel records of any officer, employee, or former employee of Defendant other than Plaintiff.
iii. Information concerning or constituting trade secrets or other confidential and proprietary business information.
iv. Other specific documents as agreed to by the parties.
v. Other specific documents as specified by ...