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Lana Isaid v. Mcneil-Ppc

November 6, 2012

LANA ISAID,
PLAINTIFF,
v.
MCNEIL-PPC, INC. AND DOES 1 TO 10, DEFENDANTS.



The opinion of the court was delivered by: Thelton Henderson R O E. Judge

STIPULATION AND [PROPOSED] ORDER REGARDING CONFIDENTIAL INFORMATION

WHEREAS, certain documents and information may be sought, produced, or exhibited by

and among the parties to the above-styled proceeding (the "Action") which relate to the parties' 25 confidential and proprietary information that may be subject to protection pursuant to Fed. R. Civ. P. 26(c); and 27 28

REGARDING CONFIDENTIAL INFORMATION CASE NO. CV 11-0663 TEH

DRINKER BIDDLE & REATH LLP STIPULATION &[PROPOSED]ORDER ATTORNEYS AT LAW SAN FRANCISCO

WHEREAS, the parties will provide a significant amount of discovery materials in this

Action and the parties agree that a protective order will facilitate a timely and efficient discovery 3 process; 4

IT IS THEREFORE STIPULATED, by the parties through their respective counsel, as 5 follows: 6 7Scope

1. This Protective Order shall govern all documents, the information contained 9 therein, and all other information produced or disclosed during this Action whether revealed in a 10 document, deposition, other testimony, discovery response or otherwise, by any party in this 11 Action (the "Supplying Party") to any other party or parties (the "Receiving Party"). 12

2. Third parties who so elect may avail themselves of, and agree to be bound by, the 13 terms and conditions of this Protective Order and thereby become a Supplying Party for purposes 14 15 of this Order.

3. The entry of this Protective Order does not prevent any party from seeking a 17 further order of this Court pursuant to Fed. R. Civ. P. 26(c).

4. Nothing herein shall be construed to affect in any manner the admissibility at trial 19 or any other court proceeding of any document, testimony, or other evidence.

Confidential Information 22 23 character that the Supplying Party believes in good faith constitutes, reflects, discloses, or

5. "Confidential Information," as used herein, means information of any type, kind or contains information subject to protection under Fed. R. Civ. P. 26(c)(1)(G), whether it is a 25 document, information contained in a document, information revealed during a deposition or 26 other testimony, information revealed in an interrogatory response, or information otherwise revealed. Any transcript of an in camera hearing shall be treated as confidential pursuant to this 2 Order. 3

6. Specific documents and discovery responses produced by a Supplying Party may 4 be designated as containing Confidential Information by marking the pages of the documents, or 5 6 copies thereof, with the words "Confidential Information • Subject to Protective Order" without obscuring any part of the text. Such a designation shall subject the document and its contents to 8 this Order. 9

7. Any material produced or provided in this Action for inspection is to be treated by 10 the Receiving Party as Confidential Information pending the copying and delivery of any copies 11 of the same by the Supplying Party to the Receiving Party. 12

8. Information disclosed at any deposition taken in connection with this Action may 7 13 14 be designated by any party as Confidential Information in accordance with the procedures set forth below. All testimony provided at deposition shall be considered Confidential Information 16 for a set period of time as set forth below and the court reporter shall mark all pages of deposition 17 testimony taken in this Action with the designation "Confidential Information - Subject to 18 Further Confidentiality Review." In order to maintain the Confidential Information status of such 19 testimony, a party must notify all other parties and the court reporter in writing within forty-five 20 21 (45) days of receipt of the final transcript of the conclusion of a witness' testimony of the specific pages and lines of the transcript that should be treated as confidential. Only those portions of the transcript so designated at the end of that 45 day period shall be deemed Confidential 24 Information.

Confidential Information Produced in Electronic Form

9. This Order will also govern the use and distribution of Confidential Electronic Information.

10. The designation by the Supplying Party of the storage medium containing Confidential Electronic Information shall serve to designate each of the files on the medium. 3

11. Where the Receiving Party seeks to share Confidential Information with 4 permissible parties as described herein, the Receiving Party shall mark printouts of Confidential 5 Electronic Information with the legend, "Confidential -- Subject to Protective Order" prior to 6 7 disseminating the Confidential Information.

12. The Receiving Party shall mark the storage medium of any permissible copies of 9 the Confidential Electronic Information with the legend "Confidential -- Subject to Protective 10 Order." 11

13. The Receiving Party shall use reasonable efforts to prevent Confidential Electronic Information from being stored in a computer to which individuals not authorized under this Order 13 14 to view Confidential Information have access. The Receiving Party shall also take reasonable steps to ensure that printouts and copies of Confidential Electronic Information maintained by the 16 Receiving ...


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