Searching over 5,500,000 cases.


searching
Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.

Zarco v. Vecoplan, LLC

United States District Court, Ninth Circuit

June 26, 2013

MARIO ALBERTO ZARCO, Plaintiff,
v.
VECOPLAN, LLC and TOTER, INC., and DOES 1 through 100, inclusive Defendant. AND RELATED CROSS-ACTIONS

Law Offices of MATHENY SEARS LINKERT & JAIME, LLP, DOUGLAS A. SEARS, ESQ. (SBN 48646), JEFFREY E. LEVINE, ESQ. (SBN 255862), Sacramento, California, Attorneys for Defendant, TOTER, INC., sued and served herein as DOES 2, 22, 32, 42, 52 and 62.

LAW OFFICES OF MICHAEL T. SHEPHERD MICAHEL T. SHEPHERD, ESQ., Attorneys for Plaintiff, MARIO ZARCO.

LAW OFFICES OF JOSEPH W. BAGGETT JOSEPH W. BAGGETT, ESQ., Attorneys, for Plaintiff, MARIO ZARCO.

KOELLER, NEBEKER, CARLSON & HALUCK, LLP JOSEPH T. SPEAKER, ESQ., Attorneys, for Defendant, VECOPLAN, LLC.

STIPULATION AND PROTECTIVE ORDER - CONFIDENTIAL AND HIGHLY CONFIDENTIAL DESIGNATIONS

CRAIG M. KELLISON, Magistrate Judge.

STIPULATED PROTECTIVE ORDER

IT IS HEREBY STIPULATED by and between Mario Zarco, ("Plaintiff"), Vecoplan, LLC. ("Vecoplan"), and Toter, Inc. ("Toter"), (hereinafter collectively the "Parties"), by and through their respective counsel of record, that in order to facilitate the exchange of information and documents which may be subject to confidentiality limitations on disclosure due to federal laws, state laws, and privacy rights, the Parties stipulate as follows:

1. A party or a non-party (the "producing party") may designate information, documents, or things as "Confidential" or "Confidential - Attorneys' Eyes Only" pursuant to the terms and conditions set forth in this Stipulated Protective Order.

2. Any document, information, or thing may be designated "Confidential" if it is in good faith determined by the producing party to contain confidential or proprietary information, including information in written, oral, electronic, graphic, pictorial, audiovisual, or other form, whether it is a document, information contained in a document, item produced for inspection, information revealed during a deposition, information revealed in an interrogatory answer, or otherwise.

3. If in good faith the producing party determines that the document, information, or thing contains confidential commercial information of such a sensitive nature that its dissemination cannot adequately be covered by the protections afforded by the "Confidential" designation, a party may designate the document, information, or thing as "Confidential - Attorneys' Eyes Only."

4. A producing party may designate any document or other tangible information or thing as "Confidential" or "Confidential - Attorneys' Eyes Only" by stamping or appending at some conspicuous place thereof with the legend "CONFIDENTIAL" or "CONFIDENTIAL - ATTORNEYS' EYES ONLY." For example, in the case of a paper document, a producing party may so mark the first page of a multipage document or each applicable page. In the case of other tangible items, a producing party may so mark any appropriate location. In the case of an electronic document, a producing party may append to that document a similar notation that does not alter the metadata associated with the document, or may place the mark "CONFIDENTIAL" or "CONFIDENTIAL - ATTORNEYS' EYES ONLY" on the outside of the medium (whether disc, hard drive, etc.) containing the document.

5. A non-producing party may also designate any document, information, or thing produced during the course of this proceeding, not already designated "Confidential" or "Confidential - Attorneys' Eyes Only, " as "Confidential" or "Confidential - Attorneys' Eyes Only" as if it were a producing party. The non-producing party shall accomplish such designation by notifying all parties in writing of the specific item so designated.

6. A producing party may designate documents, information, or things disclosed at a deposition of a producing party or one of its present or former officers, directors, employees, agents, or independent experts retained for purposes of this proceeding as "Confidential" or "Confidential - Attorneys' Eyes Only" on the record during the deposition or by notifying all parties in writing of the specific item so designated, within ten (10) business days of receiving a copy of the deposition transcript, of the specific exhibits or lines and pages of the transcript that are "Confidential" or "Confidential - Attorneys' Eyes Only."

a. If a producing party designates such materials as "Confidential" or "Confidential - Attorneys' Eyes Only" on the record, the court reporter shall indicate on the cover page of the transcript that the transcript includes "Confidential" (or, "Confidential - Attorneys' Eyes Only") information, shall list the pages and line numbers and/or exhibits of the transcript on or in which such information is contained, and shall bind the transcript in separate portions containing "Confidential, " "Confidential - Attorneys' Eyes Only, " and non-Confidential material. Further, during the period in which such "Confidential" or "Confidential - Attorneys' Eyes Only" information is discussed during the deposition, any person present during the deposition who is not authorized to receive such information pursuant to paragraphs 10 or 11 below shall be excluded from that portion of the deposition.
b. A deposition transcript and the exhibits thereto shall be presumed in their entirety as containing "Confidential" and "Confidential - Attorneys' Eyes Only" material. If, after the deposition is taken, the producing party designates any portion of the deposition transcript or exhibits as "Confidential" or "Confidential - Attorneys' Eyes Only" by giving written notice as described above, all persons receiving notice of such designation shall affix the same to the face of their copy or copies of the transcript.
c. A non-producing party may designate documents, information, or things disclosed at a deposition as "Confidential" or "Confidential - Attorneys' Eyes Only" ...

Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.