The opinion of the court was delivered by: Carla M. Woehrle United States Magistrate Judge
[PROPOSED] ORDER RE STIPULATED PROTECTIVE ORDER REGARDING CONFIDENTIAL INFORMATION NOTE CHANGES MADE BY COURT
Removed from the Superior Court of California, County of Los Angeles, Case No. BC481172
The Court having considered the Parties stipulated protective order regarding confidential information, and good cause appearing therefore, IT IS HEREBY ORDERED that the following Protective Order is in full force and effect in the present case:
1. Purpose. The purpose of this protective order is to ensure that Confidential Information, as defined below, shall be accessible only to Qualified Persons, as defined below, and that it shall be used only in connection with this proceeding.
2. Designation as Confidential. In connection with any and all discovery proceedings in this action, the Parties may designate any document, written discovery response, thing, material, testimony, or other information derived therefrom, as "Confidential" under the terms of this Stipulated Protective Order (hereinafter, "Protective Order" or "Order"). In order to designate a document as confidential, the party wishing to make such designation shall place upon the document (or on each page of a multi-page document), in a conspicuous place the words "Confidential" (or, synonymously, "Confidential Information") prior to producing a copy of such document to the other party. In lieu of marking the original of a document, if the original is not produced, the designating party may mark the copies that are produced or exchanged. Originals shall be preserved for inspection to the extent possible.
Any documents labeled "Confidential" shall be deemed confidential and governed by this Protective Order, subject to this Order's provisions regarding limitations on the marking of documents as "Confidential" and regarding termination of confidential status for any given document.
The Parties shall endeavor in good faith to label only those documents that truly merit the designation of "Confidential" because the documents include information that
(a) contains private information or (b) constitutes a trade secret, or proprietary or otherwise private or sensitive information that would allow unfair competition against the producing party if viewed by entities or individuals in competition with that party.
3. "Qualified Persons," as used within this Protective Order means:
A. any outside attorney who is retained by the receiving party and who is assisting in connection with this proceeding, including any members of such attorney's staff (e.g., paralegals, legal secretaries, and law clerks);
B. any expert witness or consultant retained or designated as such by the receiving party;
C. any court reporter or technician recording a properly-noticed ...