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Verso Paper LLC and National Union Fire Insurance v. Hireright

August 13, 2012

VERSO PAPER LLC AND NATIONAL UNION FIRE INSURANCE COMPANY OF PITTSBURGH, PA., PLAINTIFFS,
v.
HIRERIGHT, INC., DDI, INC., JOHN DOE 1, AND JOHN DOE 2, DEFENDANTS.



The opinion of the court was delivered by: The Honorable Robert N. Block United States Magistrate Judge

Rod M. Fliegel, Bar No. 168289 rfliegel@littler.com Laura E. Hayward, Bar No. 204014 lhayward@littler.com Amanda N. Fu, Bar No. 254287 afu@littler.com LITTLER MENDELSON A Professional Corporation 650 California Street, 20th Floor San Francisco, CA 94108.2693 Telephone: (415) 433-1940 Facsimile: (415) 743-6665 Christopher G. Caldwell, SBN 106790 caldwell@caldwell-leslie.com David Zaft, SBN 237365 zaft@caldwell-leslie.com Lennette Lee, SBN 263023 lee@caldwell-leslie.com CALDWELL LESLIE & PROCTOR, PC 1000 Wilshire Boulevard, Suite 600 Los Angeles, California 90017-2463 Telephone: (213) 629-9040 Facsimile: (213) 629-9022 Attorneys for Defendant HIRERIGHT, INC.

Additional Counsel listed on following page

Jay Harker (State Bar No. 167063) jharker@clausen.com Michael W. Basil (Admitted pro hac vice) mbasil@clausen.com CLAUSEN MILLER P.C. 2040 Main Street, Suite 500 Irvine, CA 92614 Telephone: (949) 260-3100 Facsimile: (949) 260-3190 Scott L. Schmookler (Admitted pro hac vice) sschmookler@gordonrees.com GORDON & REES One North Franklin, Suite 800 Chicago, IL 60603 Telephone: (312) 980-6779 Facsimile: (312) 565-6511 Attorneys for Plaintiffs VERSO PAPER LLC and NATIONAL UNION FIRE INSURANCE COMPANY OF PITTSBURGH, PA. Jeremy Johnson (State Bar No. 214989) jjohnson@bremerwhyte.com Alison K. Hurley (State Bar No. 234042) ahurley@bremerwhyte.com BREMER WHYTE BROWN & O'MEARA LLP 20320 S.W. Birch Street, 2nd Floor Newport Beach, CA 92660 Telephone: (949) 221-1000 Facsimile: (949) 221-1001 Attorneys for Defendant DDI, INC.

ASSIGNED FOR ALL PURPOSES TO JUDGE DAVID O. CARTER STIPULATION FOR AND [PROPOSED] ORDER FOR ENTRY OF AMENDED PROTECTIVE ORDER

Plaintiff Verso Paper LLC ("Verso Paper"), Plaintiff National Union Fire Insurance Company of Pittsburgh, PA. ("National Union") (collectively "Plaintiffs"), Defendant Hireright, Inc. ("HireRight") and Defendant DDI, Inc. "(DDI") (collectively "Defendants"), by and through their respective counsel of record, hereby enter into the following stipulation:

STIPULATION FOR AMENDED PROTECTIVE ORDER

Scope

1. This protective order shall govern all documents and information produced or disclosed in the above-captioned action (the "Action") by any party to the Action or third party from whom documents or information is sought (the "Designating Party") to the other party or parties ("the Receiving Party") that are designated as "Confidential Information" or "Attorneys Eyes Only Material." This protective order applies to all current and later-joined parties and any third parties producing and/or receiving documents in the Action, including without limitation Verso Paper, HireRight, DDI and National Union.

Good Cause Statement

2. Based on the claims at issue in this matter, the parties will likely request private and confidential financial information during the discovery process, including financial information related to the parties and/or third parties. Documents containing or making reference to confidential financial information are considered private and confidential and would likely cause significant harm to that party and/or infringe upon its ability to compete if such information was made available or accessible publicly and/or to the party's competitors.

3. Based on the claims at issue in this matter, the parties will likely request trade secret and/or otherwise proprietary, confidential or sensitive business information related to either party's business operations that would likely cause significant harm to that party and/or infringe upon its ability to compete if such information was made available or accessible publicly and/or to the party's competitors.

4. Based on the claims at issue in this matter, the parties will likely request information about current, past, or prospective employees that is of a confidential or private nature, including, but not limited to, current or former employees' contact information, wage information and job performance-related documentation. Such information is considered private and confidential and could violate an individual's privacy rights if it was made publicly available.

5. For the reasons set forth above, good cause exists for a protective order that will allow the parties to produce documents and information that they consider confidential, private, sensitive and/or documents that contain trade secrets while taking appropriate steps to protect the confidential, private, sensitive and/or trade secret nature of the documents and information.

Confidential Information

6. "Confidential Information" means any information contained in a document that is stamped with a "Confidential" designation. Confidential Information may include, but is not limited to:

(a) Private and confidential financial information related to the parties and/or third parties; or

(b) Proprietary, confidential or sensitive business information or information that otherwise is protected as a trade secret; or

(c) Information about current, past, or prospective employees that is of a confidential or private nature, including, but not limited to, current or former employees' contact information, wage information and job performance-related documentation.

7. "Attorneys Eyes Only Material" means any information contained in a document that is stamped with an "Attorneys Eyes Only" designation. Attorneys Eyes Only Material may include, but is not limited to highly confidential or sensitive business information that could cause financial harm to either party if disseminated to the public or a competitor.

Restrictions On Disclosure of Confidential Information and Attorneys Eyes Only

Material

8. Subject to paragraph 10, and excepting the Court and any Court personnel, Confidential Information produced under this protective order shall not be disclosed by any person who has received such Confidential Information through this Action to any other person except to:

(a) Attorneys of record for the parties and their respective associates, paralegals, clerks and employees involved in the conduct of this Action, and either party's in-house attorneys and attorneys employed by its corporate parents and/or corporate ...


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