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Jerame Mcdaniel, On Behalf of Himself and All Others Similarly Situated v. the Reinalt-Thomas Corporation (Doing Business As Discount

April 15, 2013

JERAME MCDANIEL, ON BEHALF OF HIMSELF AND ALL OTHERS SIMILARLY SITUATED, PLAINTIFFS,
v.
THE REINALT-THOMAS CORPORATION (DOING BUSINESS AS DISCOUNT TIRE/AMERICA'S TIRE), SOUTHERN CALIFORNIA DISCOUNT TIRE CO., INC., AND DOES 1-50, INCLUSIVE, DEFENDANTS.



The opinion of the court was delivered by: Honorable Patrick J. Walsh United States Magistrate Judge

STIPULATION FOR PROTECTIVE ORDER; AND [PROPOSED] ORDER THEREON

Complaint Filed: July 2, 2012

Judge: Terry J. Hatter, Jr.

Courtroom: 17 (Spring Street courthouse) Magistrate Judge: Patrick J. Walsh Courtroom: 23 (Spring Street courthouse) Trial Date: Not Set [DISCOVERY MATTER]

Upon agreement of counsel for DEFENDANTS THE REINALT-THOMAS CORPORATION AND SOUTHERN CALIFORNIA DISCOUNT TIRE CO., INC. ("DEFENDANTS") and PLAINTIFF JERAME McDANIEL ("PLAINTIFF"), and deeming it just and proper to do so, IT IS HEREBY ORDERED:

1. Any party to this litigation and any third-party shall have the right to designate as "Confidential" and subject to this Order any information, document, or thing, or portion of any document or thing which the producing party otherwise believes in good faith: (a) contains trade secrets, competitively sensitive technical, marketing, financial, sales or other confidential business information, or (b) contains private or confidential personal information, including, but not limited to, home addresses, electronic mail address, Social Security numbers, financial account numbers, driver's license numbers, dates of birth, employment information, or (c) contains information received in confidence from third parties, or (d) which the producing party otherwise believes in good faith to be entitled to protection under Rule 26(c)(1)(G) of the Federal Rules of Civil Procedure. Any party to this litigation or any third-party covered by this Order, who produces or discloses any Confidential Material, including without limitation any information, document, thing, interrogatory answer, admission, pleading, or testimony, shall mark the same with the foregoing or similar legend: "CONFIDENTIAL" or "CONFIDENTIAL -- SUBJECT TO PROTECTIVE ORDER" (hereinafter "Confidential Material").

2. Any party to this litigation and any third-party shall have the right to designate as "CONFIDENTIAL-ATTORNEYS' EYES ONLY" and subject to this Order any information, document, or thing, or portion of any document or thing which the producing party otherwise believes in good faith contains extremely sensitive financial, business or personal information. Any party to this litigation or any third party who is covered by this Order, who produces or discloses any Attorneys' Eyes Only material, including without limitation any information, document, thing, interrogatory answer, admission, pleading, or testimony, shall mark the same with the foregoing or similar legend: "CONFIDENTIAL -- ATTORNEYS' EYES ONLY" or "CONFIDENTIAL ATTORNEYS' EYES ONLY -- SUBJECT TO PROTECTIVE ORDER" (hereinafter "Attorneys' Eyes Only Material").

3. Any party to this litigation and any third-party that designates information, documents, items or oral or written communications for protection under this Order must take care to limit any such designation to specific material that qualifies under the appropriate standards. To the extent it is practical to do so, the designating party must designate for protection only those parts of material, documents, items, or oral or written communications that qualify -- so that other portions of the material, documents, items, or communications for which protection is not warranted are not swept unjustifiably within the ambit of this Order.

If it comes to a designating party's attention that information or items that it designated for protection do not qualify for protection at all or do not qualify for the level of protection initially asserted, that designating party must promptly notify all other parties that it is withdrawing the mistaken designation.

4. All Confidential Material shall be used by the receiving party solely for purposes of the prosecution or defense of this action, shall not be used by the receiving party for any business, commercial, competitive, personal or other purpose, and shall not be disclosed by the receiving party to anyone other than those set forth in Paragraph 4, unless and until the restrictions herein are removed either by written agreement of counsel for the parties, or by Order of the Court.

5. Unless otherwise ordered by the court or permitted in writing by the designating party, a receiving party may disclose any information or item designated "CONFIDENTIAL" only to:

a. Counsel for the parties, including outside counsel (herein defined as any attorney at the parties' outside law firms) and relevant in-house counsel for the parties, as well as employees of all such Counsel to whom it is reasonably necessary to disclose the information for this litigation;

b. Experts or consultants of the receiving party to whom disclosure is reasonably necessary for this litigation, provided they have signed a non-disclosure agreement in the form attached hereto as Exhibit A;

c. Secretarial, paralegal, clerical, duplicating and data processing personnel of the foregoing;

d. The Court and its personnel;

e. Any deponent may be shown or examined on any information, document or thing designated Confidential if it appears that the witness authored or received a copy of it, was involved in the subject matter described therein or is employed by the party who produced the information, document or thing, or if the producing party consents to such disclosure;

f. The author or recipient of a document containing the information or a custodian or other person who otherwise possessed or knew the information;

g. Vendors retained by or for the parties to assist in preparing for pretrial discovery, trial and/or hearings including, but not limited to, court reporters, litigation support personnel, jury consultants, individuals to prepare demonstrative and audiovisual aids for use in the courtroom or in depositions or mock jury sessions, as well as their staff, stenographic, and clerical employees whose duties and responsibilities require access to such materials; and

h. The parties. In the case of parties that are corporations or other business entities, "party" shall mean executives who are required to participate in ...


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