Thomas E. Soule, Edelman Combs Latturner & Goodwin LLC, Chicago, Illinois, Attorneys for plaintiff.
Robert L. Green, Green & Hall APC, Santa Ana, California, Attorneys for defendants.
JEAN P. ROSENBLUTH, Magistrate Judge.
This Court, mindful of holdings relevant to the entry of protective orders regarding confidential information (see, e.g., In re Roman Catholic Archbishop of Portland in Oregon, 661 F.3d 417, 424-425 (9th Cir. 2011)), and having found good cause under Fed.R.Civ.P. 26(c) to protect from disclosure (a) sensitive information relating to the sickness or death of pets, (b) sensitive personal financial information (such as, e.g., account numbers and social security numbers), and (c) sensitive corporation information (such as, e.g., trade secrets regarding the production of chicken jerky dog treats, financial records, and the content of contracts), now enters the following protective order, as follows:
1. This order is for the convenience of the parties and this Court. Any member of the public, any party to this action, and any third-party participant in discovery may move, at any time, for any relief from this order, modification of this order, or the public disclosure of any document in the record that is filed under seal. This Court will, on good cause shown, provide such relief to the public, or the parties, taking into due consideration the interests of justice, of the public, and of the parties. This Court may also enter such orders as it sees fit, on its own motion, relevant to the production or publication of documents.
2. All materials produced or adduced in the course of discovery, including initial disclosures, responses to discovery requests, deposition testimony and exhibits, and information derived directly therefrom (hereinafter collectively "documents") - and including any documents produced through third-party discovery (by subpoena or otherwise) shall be subject to this order concerning "Confidential Information, "consistent with all applicable rules of procedure.
3. "Confidential Information" means information designated as "CONFIDENTIAL-SUBJECT TO PROTECTIVE ORDER" by the producing party that falls within one or more of the following categories:
(A) information prohibited from disclosure by statute;
(B) information that reveals trade secrets;
(C) research, technical, commercial or financial information that the party has maintained as confidential;
(D) medical information concerning any individual (including animals);
(E) personal identity information;
(F) income tax returns (including attached schedules and forms), W-2 forms and 1099 forms; or
(G) personnel or employment records of a person who is not a party to the case.
4. Information or documents that are available to the public may not be designated as ...