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Maritza Duarte, An Individual v. W.M. Barr & Company

January 10, 2013

MARITZA DUARTE, AN INDIVIDUAL, PLAINTIFFS,
v.
W.M. BARR & COMPANY, INC., A TENNESSEE CORPORATION; AND DOES 1 THROUGH 50, INCLUSIVE DEFENDANTS.



The opinion of the court was delivered by: Hon. Jay C. Gandhi Magistrate Judge OF The United States District Court- Central District OF California

[Assigned to the Hon. George H. Wu, Court Room "10"] [PROPOSED]

ORDER ENTERING STIPULATED PROTECTIVE ORDER REGARDING CONFIDENTIALITY OF DOCUMENTS AND INFORMATION

Pursuant to the Stipulated Protective Order Regarding Confidentiality of Documents and Information ("Stipulation") among counsel for plaintiff, MARITZA DUARTE, and defendant, W.M. BARR & COMPANY, INC., attached hereto as Exhibit "1", and after the finding of GOOD CAUSE, the Court makes the following ORDER:

1. SCOPE OF THIS ORDER.

All discovery, including any documents and information provided as part of the initial disclosures pursuant to Fed. Rules Civ.Proc., rule 26, 28 U.S.C.A., answers to interrogatories, responses to requests for admission, deposition testimony, deposition transcripts and exhibits, other responses to requests for information and/or other written information, produced in this action, including any such material initially produced in any other litigation, action, arbitration, investigation, or proceeding of any kind (hereinafter, collectively, "Materials"), shall be subject to this Order and may be designated by the party producing the information (the "Producing Party") as "Confidential Information" under this Order. This Order does not restrict the use or dissemination of information obtained legally from sources other than the parties and/or their counsel, and nothing in this Order shall limit or restrict a Producing Party's rights to use or disseminate its own Materials however designated for purposes of this litigation.

2. CONFIDENTIAL INFORMATION.

Information marked "Confidential Information" shall include testimony about any Materials that contain, describe, evidence, identify, or refer to information of a confidential or proprietary nature, or otherwise entitled to protection under Fed. Rules Civ.Proc., rule 26, subsection c, 28 U.S.C.A. Parties and non-parties may designate any information supplied in any form, or any portion thereof, as Confidential Information for purposes of this action. Such designation shall constitute a representation to the Court that counsel believes in good faith that the information constitutes Confidential Information. The parties and non-parties shall make a good faith effort to designate information so as to provide the greatest level of disclosure possible, but still preserve confidentiality as appropriate.

3. COPIES INCLUDED.

Any copies or reproductions, excerpts, summaries, or other documents or media that paraphrase, excerpt or contain "Confidential Information" shall be treated as "Confidential Information" pursuant to this Order.

4. ALL INFORMATION TO BE USED ONLY FOR THIS CASE.

"Confidential Information" produced in this action shall be used only for purposes of this action and for no other purpose, case or claim, and shall not, without leave of this Court or by agreement of the parties, be disclosed to any person or entity, except as is herein provided. The parties in this action shall ensure that use and dissemination of "Confidential Information" produced in this action remain strictly limited to this action and that such "Confidential Information" does not become in any way available in other actions.

5. LIMITATION ON DISCLOSURE OF CONFIDENTIAL INFORMATION.

"Confidential Information" may be disclosed only to the following persons:

(a) The Court, including associated personnel necessary to assist the Court in its function, and the jury;

(b) Outside counsel for any party, including associated personnel necessary to assist outside counsel in this action, such as litigation assistants, paralegals, and secretarial or other clerical personnel;

(c) Litigation support services, including outside copying services, court reporters, stenographers or companies engaged in the business of supporting computerized or electronic litigation discovery or trial preparation, retained by a party or its counsel for the purpose of assisting that party in this action;

(d) Consulting or testifying experts, including associated personnel necessary to assist experts in this action, such as litigation assistants, paralegals, ...


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