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Robin Love v. Kaiser Foundation Hospitals

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA OAKLAND DIVISION


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

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or documents by him/her for any purpose other than this litigation and has enjoined the disclosure of that information or documents to any other person.

6. The Confidential Information may be displayed to and discussed with the 18 persons identified in Paragraphs 4(c) and (d) only on the condition that prior to any such 19 display or discussion, each such person shall be asked to sign an agreement to be bound 20 by this Order in the form attached hereto as Exhibit A. In the event such person refuses 21 to sign an agreement in the form attached as Exhibit A, the party desiring to disclose the 22

7. The disclosure of a document or information without designating it as 24 "confidential" shall not constitute a waiver of the right to designate such document or 25 information as Confidential Information provided that the material is designated pursuant 26 to the procedures set forth herein no later than the latter of fourteen (14) days after the 27 close of discovery or fourteen (14) days after the document or information's production. 28

If so designated, the document or information shall thenceforth be treated as Confidential

Confidential Information may seek appropriate relief from the Court.

Information subject to all the terms of this Stipulation and Order. 2

8. All information subject to confidential treatment in accordance with the terms of 3 this Stipulation and Order that is filed with the Court, and any pleadings, motions or other 4 papers filed with the Court disclosing any Confidential Information, shall be filed under 5 seal to the extent permitted by law (including without limitation any applicable rules of 6 court) and kept under seal until further order of the Court. To the extent the Court 7 requires any further act by the parties as a precondition to the filing of documents under 8 seal (beyond the submission of this Stipulation and Order Regarding Confidential 9

Information), it shall be the obligation of the producing party of the documents to be filed 10 with the Court to satisfy any such precondition. Where possible, only confidential 11 portions of filings with the Court shall be filed under seal.

9. At the conclusion of litigation, the Confidential Information and any copies thereof shall be promptly (and in no event later than thirty (30) days after entry of final judgment no longer subject to further appeal) returned to the producing party or certified as destroyed, except that the parties' counsel shall be permitted to retain their working files on the condition that those files will remain confidential.

The foregoing is entirely without prejudice to the right of any party to apply to the

Court for any further Protective Order relating to confidential information; or to object to 20 the production of documents or information; or to apply to the Court for an order 21 compelling production of documents or information; or for modification of this Order.

This Order may be enforced by either party and any violation may result in the 23 imposition of sanctions by the Court.

Dated: April 4, 2013 JUSTICE FIRST, LLP 2 Oakland, California Attorneys for Plaintiff Robin Love By: ________/s/_Jenny Huang_______ Jenny C. Huang 180 Grand Avenue, Suite 1300 Oakland, CA 94612 Dated: April 4, 2013 STEPHEN D. SCHEAR 7 Oakland, California Attorneys for Plaintiff Robin Love By: ________/s/_Stephen Schear Stephen Schear 2831 Telegraph Avenue Oakland, CA 94609 Dated: MARION'S INN, LLP 12 Oakland, California Attorneys for Defendants By: ________/s/ David Rosenberg-Wohl __ David M. Rosenberg-Wohl 1611 Telegraph Avenue, Suite 707 Oakland, CA 94612

PURSUANT TO STIPULATION, IT IS SO ORDERED.

Dated: April ___, 2013 _____________________________________ 20

YVONNE GONZALEZ ROGERS

EXHIBIT A

ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

I have been informed by counsel that certain documents or information to be disclosed to me in connection with the matter entitled Love v. Kaiser Foundation Hospitals, et al. Case No. 12-cv-05679 (YGR) have been designated as confidential. I 7 have been informed that any such documents or information labeled "CONFIDENTIAL 8 -- PRODUCED PURSUANT TO PROTECTIVE ORDER" are confidential by Order of 9 the Court.

I hereby agree that I will not disclose any information contained in such documents to any other person. I further agree not to use any such information for any purpose other than this litigation.

DATED: __________________

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15

City and State where sworn and signed: _________________________________

USTICE

Printed name: ________________________________

J

[printed name]

Signature: ___________________________________

[signature]

Signed in the Presence of: ____________________________ (counsel of record)

20130416

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