LOVE & ERSKINE, LLP, RICHARD A. LOVE, KATHLEEN M. ERSKINE, Los Angeles, California, Attorneys for Plaintiff DAVID GUZMAN.
LITTLER MENDELSON, P.C., LARA K. STRAUSS, JOSHUA D. LEVINE, San Diego, CA, Attorneys for Defendants SYSCO CORPORATION and SYSCO VENTURA, INC.
STIPULATED CONFIDENTIALITY AGREEMENT AND PROTECTIVE ORDER; [PROPOSED] ORDER
JAY C. GANDHI, Magistrate Judge.
Plaintiff David Guzman ("plaintiff") and defendants Sysco Corporation and Sysco Ventura, Inc. ("defendants"), by and through their respective counsel, hereby stipulate as follows:
WHEREAS, in connection with discovery in this case, the parties have sought or are likely to seek certain documents and/or information which the other party contends is private, highly confidential and/or proprietary;
WHEREAS, each party contends that the documents and/or information sought are relevant to the subject matter of this litigation or reasonably calculated to lead to the discovery of admissible evidence;
WHEREAS, the parties desire to protect the confidentiality of such documents and information and to ensure that the parties can obtain and pursue discovery with the minimum of delay and expense;
NOW, THEREFORE, it is hereby stipulated and agreed as follows:
1. Documents and information (including documents in electronic format) which are furnished to any party by any other party, or by third parties to this litigation through subpoenas duces tecum, and are marked or otherwise designated as "Confidential" (including documents that are produced, deposition transcripts and discovery responses), and any summaries or descriptions of such documents and information, (hereinafter collectively referred to as "Confidential Documents") are confidential, or are deemed by the party producing the documents or information, or to whom the documents or information pertain, to constitute or contain confidential information, and shall be used solely for the purposes of prosecuting or defending this action, and for no other reason. Documents which have been or can be marked and designated as "Confidential" by either party are:
a. Plaintiff's medical, psychological and/or psychiatric records;
b. Documents which record, reflect or otherwise document any "trade secrets, " or other competitive or private business information of defendants;
c. Documents which record, reflect or otherwise document matters which involve the privacy interests or rights of any third party, not a party to this action.
Said Confidential Documents shall not be used for any other business and/or purpose except pursuant to Paragraphs 3, 4, and 5 of this Confidentiality Agreement and Protective Order.
2. Except as provided in Paragraphs 3, 4, and 5, below, all such Confidential Documents shall be held in confidence in perpetuity and may be disclosed ...