SHERRY DOBROSKY, an individual, on behalf of herself and on behalf of all persons similarly situated, Plaintiff,
ARTHUR J. GALLAGHER SERVICE COMPANY, LLC., a Delaware Limited Liability Company, and DOES 1 through 50, inclusive, Defendant.
Douglas R. Hart, SBN 115673 Katherine A. Roberts, SBN 259486 Heather C. Aspell, SBN 274489 SIDLEY AUSTIN LLP, Los Angeles, California. Attorneys for ARTHUR J. GALLAGHER SERVICE COMPANY, LLC., a Delaware Limited Liability Company, and DOES 1 through 50, inclusive
BLUMENTHAL, NORDREHAUG & BHOWMIK, APARAJIT BHOWMIK, Attorney for Plaintiff.
STIPULATED PROTECTIVE ORDER RE: PROTECTION OF CONFIDENTIAL INFORMATION
SHERI PYM, Magistrate Judge.
TO ALL PARTIES OF RECORD AND THIS HONORABLE COURT:
Disclosure and discovery activity in this action are likely to involve production of confidential, proprietary, or private information for which special protection from public disclosure and from use for any purpose other than prosecuting this litigation would be warranted. Accordingly, the Parties hereby stipulate to and petition the Court to enter the following Stipulated Protective Order. The Parties acknowledge that this Order does not confer blanket protections on all disclosures or responses to discovery and that the protection it affords extends only to the limited information or items that the producing party deems to be: (1) protected by the right of privacy of Defendant Arthur J. Gallagher Service Company LLC's ("Defendant's'") current and former employees; (2) proprietary; or (3) contain trade secrets. As such, IT IS HEREBY STIPULATED AND AGREED by and between Plaintiff Sherry Dobrosky ("Plaintiff"), through her counsel, on the one hand, and Defendant, through its counsel, on the other, that the Parties will maintain the confidentiality of, and use solely for the purpose of litigating the present lawsuit or other employment-related claims Plaintiff may pursue against Defendant, any confidential or proprietary information which the Parties mark as "confidential, " "proprietary, " or "subject to protective order, " (hereinafter referred to as "Confidential Information"). The Parties may only mark as Confidential Information the limited information or items that the producing party deems to be (1) protected by the right of privacy, including but not limited to, private contact and identifying information, and/or third-party personnel data and information, (2) proprietary, (3) contain trade secrets. The party designating the material as confidential bears the burden of establishing the confidential nature of the documents.
Additionally, the Parties agree upon the following, procedures, terms and conditions:
1. In accordance with the limitations and procedures set forth below, access to the Confidential Information shall be limited to the following persons or parties:
a. Attorneys of record for the Parties;
b. Paralegals, secretaries, and/or process servers regularly employed by the Parties' counsel of record;
c. Plaintiff and Defendant; d. Experts or paid consultants regarding this litigation;
e. Witnesses in a deposition or at trial who have a specific and necessary case-related reason to review the Confidential Information;
2. All persons identified in sub-paragraphs 1(c) - 1(e) who in the course of this action are given access to Confidential Information, shall be required to read the Stipulation and agree to be bound thereby by executing the "Acknowledgment and Agreement To Be Bound By Protective Order, " attached hereto as Exhibit A.
3. Any responses to interrogatories, requests for admissions, or demands for inspection and pleadings that disclose the content of Confidential Information shall be restricted and marked as Confidential Information.
4. If Confidential Information is disclosed during a deposition, counsel of record for the Designating Party shall make arrangements, or when appropriate request the Court to make arrangements, to ensure that only the deponent, counsel for the deponent, court reporter, and Qualified Persons identified in Paragraph 1 above, are present, and ask that such testimony be bound separately and ...