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Steven Quinlan, Individually and On Behalf of All Others Similarly Situated v. Macy's Corporate Services

December 3, 2012

STEVEN QUINLAN, INDIVIDUALLY AND ON BEHALF OF ALL OTHERS SIMILARLY SITUATED,
PLAINTIFF,
v.
MACY'S CORPORATE SERVICES, INC., AND DOES 1 THROUGH 100, INCLUSIVE
DEFENDANTS.



The opinion of the court was delivered by: Hon. Jacqueline Chooljian United States Magistrate Judge

Document 24 Filed 12/03/12 Page 1 of 8 Page ID #:160 Case No. CV12 0737 Honorable Dean D. Pregerson STIPULATED PROTECTIVE ORDER Complaint Filed: Dec. 21, 2011 Removed: Jan. 27, 2012 Discovery Cutoff: None Motion Cutoff: None Trial Date: None

STIPULATED PROTECTIVE ORDER

Subject to the approval of this Court, the parties hereby stipulate to the following protective order:

1. Good cause exists as follows: during the pendency of this case, the parties anticipate that they will produce to one another certain information and documents that the producing party believes contain confidential and/or proprietary information the unprotected disclosure of which could have an adverse and detrimental impact on the legitimate business of the disclosing party and the constitutionally-enshrined privacy interests of third parties to the litigation. Such information includes, but is not limited to, information regarding Defendant's California employees who elected to participate in Defendant's voluntary arbitration program (Solutions InSTORE), the identity and personal contact information for Defendant's California employees and certain business information not released to the public or in the public domain such as sales and shortage numbers relating to its California stores. A party disclosing any such information, which the party in good faith reasonably believes to be confidential may designate it as "Confidential" (hereinafter "Confidential Information"). The parties acknowledge that this Order does not confer blanket protections on all disclosures or responses to discovery and that the protection it affords from public disclosure and use extends only to the limited information or items that are entitled to confidential treatment under the applicable legal principles. The parties agree that the following limitations on the disclosure of such Confidential Information should be imposed.

2. Documents, discovery responses, information and materials produced hereafter and deposition testimony in the future designated as Confidential Information shall be subject to the provision of this Stipulated Protective Order. If only a portion of a deposition transcript or other discovery item contains Confidential Information, only that portion will be subject to this Stipulated Protective Order. However, the protections conferred by this Order do not cover the following information: (a) any information that is in the public domain at the time of disclosure to the receiving party or becomes part of the public domain after its disclosure to the receiving party as a result of publication not involving a violation of this Order, including becoming part of the public record through trial or otherwise; and (b) any information known to the receiving party prior to the disclosure or obtained by the receiving party after the disclosure from a source who obtained the information lawfully and under no obligation of confidentiality to the designating party.

3. All copies of documents, discovery responses or other materials produced and designated as containing Confidential Information, and all transcripts of depositions in which Confidential Information has been designated, shall have clearly stamped thereon "Confidential" on each page that contains protected material in a manner which avoids any interference with the legibility of the material.

4. The Confidential Information contained in documents, discovery responses, deposition transcripts and materials subject to this Protective Order shall be in connection with this case only for prosecuting, defending, or attempting to settle this litigation and may be disclosed only as follows:

A. Confidential Information may be disclosed to the parties, their attorneys, and to members of the paralegal, secretarial or clerical staff (including shorthand reporters), as well as outside vendors assisting such counsel. Outside vendors shall agree in writing to be bound by the terms and provisions of this Stipulated Protective Order and to subject themselves to the jurisdiction of this Court for purposes of enforcement of this Protective Order.

B. Counsel may disclose Confidential Information to independent experts specifically retained for the purposes of this litigation to assist counsel in the prosecution and/or defense of this action or any appeal filed herein. Such experts shall agree in writing to be bound by the terms and provisions of this Stipulated Protective Order and to subject themselves to the jurisdiction of this Court for purposes of enforcement of this Protective Order.

C. Confidential Information may be disclosed to the Court, pursuant to Paragraph 7 of this Stipulated Protective Order.

D. Confidential Information may be disclosed to the author or recipient of the document containing the Confidential Information or to a custodian or other person who otherwise lawfully obtained the information.

E. Except as provided in subpart A through D of this paragraph, the parties, their counsel, and others with permitted access to the Confidential Information shall not disclose it to any person or use it for any purpose except the prosecution or defense of this litigation.

5. Except as limited below, Confidential Information may be used or elicited in party depositions and also in the preparation of non-party witnesses for deposition if the witness agrees in writing or on the record to preserve the confidentiality of such Confidential Information and not to use any such information for any purpose except this litigation.

6. The use of Confidential Information in the taking of depositions, including their use as exhibits in such depositions, shall not cause such documents or information to ...


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