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Kelly Jackson, An Individual; Georgina Polo, An Individual v. Casden Burbank

March 19, 2013

KELLY JACKSON, AN INDIVIDUAL; GEORGINA POLO, AN INDIVIDUAL;
WENDY LUNGARO, AN INDIVIDUAL LIBORIO LUNGARO, AN INDIVIDUAL; PLAINTIFF,
v.
CASDEN BURBANK, LLC, A DELAWARE CORPORATION,
CASDEN PROPERTY MANAGEMENT, INC., A CALIFORNIA CORPORATION, AND
DOES 1 THROUGH 10, INCLUSIVE DEFENDANTS.



The opinion of the court was delivered by: Judge Michael W. Fitzgerald

TO THE COURT:

STIPULATED PROTECTIVE ORDER

Courtroom: 1600

The parties hereto, Plaintiffs Kelly Jackson, Georgina Polo, Wendy Lungaro and Liborio Lungaro, (collectively hereafter referred to as "Plaintiffs"), on the one hand, and Defendants Casden Burbank, LLC and Casden Property Management, Inc. (collectively hereafter referred to as "Defendants"), on the other hand, by and through their respective counsel of record, hereby stipulate to the entry of a Protective Order pursuant to Federal Rule of Civil Procedure 26(c).

There is good cause for this Protective Order because the disclosures and discovery in this case will likely involve the production of confidential, proprietary, or private information concerning, among other topics, including personal information such as the names, addresses and telephone numbers of current and former tenants of Defendants' property commonly referred to as "The Empire Landing Apartments," the familial status of current and former tenants of Defendants' property commonly referred to as "The Empire Landing Apartments," as well as proprietary information of Defendants, including trade secrets and other confidential proprietary and private commercial and financial information which is not generally subject to public disclosure. Special protection of these categories of information from public disclosure and/or from use for any purpose other than prosecuting or defending this litigation is warranted. Accordingly, the parties hereby Stipulate to the Court entering the following Protective Order. This Order does not confer blanket protections on all disclosures or responses to discovery and the protection it affords extends only to the limited information or items that are entitled under the applicable legal principles to treatment as confidential. The Protective Order will contain the following terms and conditions

STIPULATION

1. Proceedings and Information Governed. This Stipulation and Order will govern any document, information, or other thing furnished or produced by any party, including third parties, to any other party in connection with this action that might reveal confidential information, including, but not limited to, the contact information (including name, address, and telephone number) of current and former tenants of The Empire Landing Apartments, the familial status of current and former tenants of The Empire Landings Apartments, as well as proprietary information of Defendants. This Stipulation and Order will also govern business information, including but not limited to trade secrets, proprietary information, and financial information which may be produced in this action and designated by the producing party as "confidential information or material" as defined below. The information protected includes, but is not limited to, information contained in initial disclosures, responses to written discovery; deposition testimony and exhibits; and all copies, extracts, summaries, compilations, designations, and portions of the foregoing.

2. Confidential Information or Material Defined. For purposes of this stipulation and accompanying order, "confidential information or material" will mean all information or material that:

a. Is produced for or disclosed to a receiving party (Plaintiffs or any Defendant); and

b. A party (Plaintiffs or any Defendant) reasonably and in good faith believes it to constitute confidential information as set forth in Rule 26(c) of the Federal Rules of Civil Procedure, or otherwise constitutes business proprietary and/or confidential material or financial information, whether embodied in physical objects, documents, or other factual knowledge of persons, and specifically shall include but not necessarily be limited to third party employee personnel information; and

c. Has been designated as confidential information by the producing party in compliance with this Stipulation and Order, and in advance of its production.

3. Designation of Confidential Information or Material. The producing party may designate confidential information by stamping or affixing to the physical objects, documents, discovery responses, or deposition transcripts a stamp or other inscription that states: "Confidential" and the case number - "CV12-06936 MWF (JCGx)".

For written material, documents, or other tangible items, the designation of confidential information or material must be made when the material is produced to the receiving party. The designation of any particular page of written material shall indicate that all information contained on that page is designated "confidential" unless otherwise indicated.

For information not reduced to written material, document, or other tangible item, or information that can not be conveniently designated as set forth in this paragraph, the producing party must designate the confidential information by giving written notice to the receiving party at the time the confidential information is produced. The written notice must clearly identify that part of the information being produced that is designated as confidential.

4. Party's Own Information. The restrictions on the use of confidential information established by this stipulation and order apply only to the use by a party of confidential information received from another party to this action, or from a non-party to this action, and shall not apply to the use by a party of his/her/its own information.

5. Persons Authorized to Receive Confidential Information and Material. For purposes of this Stipulation and Order, the term "qualified recipient" of information and material that has been designated pursuant to the terms of this stipulation and order shall mean:

(a) The parties to this action, including officers, directors, and other employees of the party to whom disclosure of confidential information is deemed necessary by that party for purposes of this action only;

(b) The attorneys of record in this action, attorneys employed in-house by or on behalf of the parties, any attorneys retained by the parties in this action to consult on the litigation, their respective partners, associates, clerks, legal assistants, secretaries, and stenographic and support personnel, and such other ...


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