The opinion of the court was delivered by: John E. McDermott United States Magistrate Judge
STIPULATED PROTECTIVE ORDER
Plaintiff Clear Channel Outdoor, Inc. ("CCO") and Defendants 993
Schumacher, LLC and Alexander Golbahar (collectively, "Defendants"), by and through their respective counsel of record, hereby STIPULATE AND AGREE, and accordingly request, that the Court enter the following order:
1. PURPOSES AND LIMITATIONS
Disclosure and discovery activity in this action are likely to involve the production of confidential, proprietary, and/or private information for which special protection from public disclosure and from use for any purpose other than prosecuting this litigation is warranted. Accordingly, the parties hereby stipulate to and petition the Court to enter the following Stipulated Protective Order. The parties acknowledge that this Order does not confer blanket protections on all disclosures or responses to discovery and that the protection it affords extends only to the limited information or items that are entitled under the applicable legal principles to treatment as confidential.
2.1 Party: Any party to this action, including all of its officers, directors, employees, consultants, retained experts, and outside counsel (and their support staff).
2.2 Disclosure or Discovery Material: All items or information, regardless of the medium or manner generated, stored, or maintained (including, among other things, testimony, transcripts, or tangible things) that are produced or generated in disclosures or responses to discovery in this matter.
2.3 "Confidential" Information or Items: Any confidential research, development, or commercial information, confidential information of non-parties, financial information, intellectual property, including but not limited to, information consisting of trade secrets (as that term is defined in California Civil section 3426.1(d)), or other highly confidential documents which relate to current or future business plans or strategies, the disclosure of which to those other than the Designating Party would be likely to cause competitive or business injury to the Designating Party, information protected by the right of privacy (as governed by, among other things, California Code of Civil Procedure section 1985.3, et seq., the California Financial Information Privacy Act, California Financial Code section 4052.5, and the Gramm-Leach-Bliley Act, 15 U.S.C. § 6801, et seq.), and any other commercially sensitive information that would qualify for protection under Federal Rule of Civil Procedure 26(c). Notwithstanding the foregoing, Confidential Information shall not mean Disclosure or Discovery Materials produced or disclosed that are or become, without violating this Protective Order, and apart from production or disclosure in connection with this action, a matter of public record or publicly available by law or otherwise.
2.4 Receiving Party: A Party that receives Disclosure or Discovery Material from a Producing Party.
2.5 Producing Party: A Party or non-party that produces Disclosure or Discovery Material in this action.
2.6 Designating Party: A Party or non-party that designates Disclosure or Discovery Materials as "Confidential."
2.7 Protected Material: Any Disclosure or Discovery Material that is designated as "Confidential."
2.8 Outside Counsel: Attorneys who are not employees, or In-House Counsel, of a Party but who are attorneys retained to represent or advise a Party in this action.
2.9 In-House Counsel: Attorneys who are employees of a Party in this action.
2.10 Expert: A person with specialized knowledge or experience in a matter pertinent to the litigation who has been retained by a Party or its counsel to serve as an expert witness or as a consultant in this action.
2.11 Professional Vendors: Persons or entities that provide litigation support services (e.g., photocopying; videotaping; translating; preparing exhibits or demonstrations; organizing, storing, retrieving data in any form or medium; etc.) and their employees and subcontractors. Professional vendors include a professional jury or trial consultant retained in this litigation.
3. DESIGNATING PROTECTED MATERIAL
3.1 Manner and Timing of Designations. Except as otherwise provided in this Order, or as otherwise stipulated or ordered, material that qualifies for protection under this Order should be clearly so designated before the material is disclosed ...