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Robin Love v. Kaiser Foundation Hospitals

April 16, 2013

ROBIN LOVE, PLAINTIFF,
v.
KAISER FOUNDATION HOSPITALS, ET AL., DEFENDANTS.



STIPULATED PROTECTIVE ORDER

The parties to the above-entitled action, by way of their respective attorneys, HEREBY STIPULATE AND AGREE that the following restrictions and procedures 3 shall apply to certain information, documents and excerpts from documents supplied by 4 the parties to each other in response to discovery requests: document, information revealed in an interrogatory response or information revealed 7 during a deposition as confidential if counsel determines, in good faith, that such 8 designation is necessary to protect the interests of the client. Information and documents 9 designated by a party as confidential will be stamped "CONFIDENTIAL."

"Confidential" information or documents may be referred to collectively as "confidential 11 information." 12

Information disclosed will be held and used by the person receiving such information solely for use in connection with the above-captioned action.

3. In the event a party challenges another party's confidential designation, counsel shall make a good faith effort to resolve the dispute, and in the absence of a resolution, the challenging party may thereafter seek resolution by the Court. Nothing in this 18 Protective Order constitutes an admission by any party that Confidential Information 19 disclosed in this case is relevant or admissible. Each party specifically reserves the right 20 to object to the use or admissibility of all Confidential Information disclosed, in 21 accordance with applicable law and Court rules. 22 any person, except:

litigation; 28

1. Counsel for any party may designate any document, information contained in a 2. Unless ordered by the Court, or otherwise provided for herein, the Confidential 13 LLP , 14 IRST F 15 USTICE 16 J 17 4. Information or documents designated as "confidential" shall not be disclosed to a. The requesting party and counsel, including in-house counsel; b. Employees of such counsel assigned to and necessary to assist the c. Consultants or experts assisting in the prosecution or defense of the matter, to the extent deemed necessary by counsel; 2

3 actions, except that such a person may only be shown that Confidential Information 4 during and in preparation for his/her testimony and may not retain the Confidential 5

e. The Court (including any clerk, stenographer, or other person having

d. Any person from whom testimony is taken or is to be taken in these Information; and access to any Confidential Information by virtue of his or her position with the Court) or 8 the jury at trial or as exhibits to motions.

5. Prior to disclosing or displaying the Confidential Information to any person, 10 counsel shall: 11 documents; and USTICE J

a. inform the person of the confidential nature of the information or LLP ,

b. inform the person that this Court has enjoined the use of the information

IRST

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