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Gomez v. Cecil Main Street LLC

United States District Court, Ninth Circuit

July 9, 2013

SALVADOR GOMEZ, JR., Plaintiff,
v.
CECIL MAIN STREET LLC, a Delaware limited liability corporation; and MAIN STREET HOTEL MANAGEMENT, LLC, a California limited liability corporation; Defendants.

PROPOSED PROTECTIVE ORDER

DAVID T. BRISTOW, District Judge.

The Court, having considered the Stipulation for Protective Order submitted by the Parties, and finding good cause, hereby ORDERS as follows:

I. DEFINITIONS

1. This Order shall govern the production, use and disclosure of all material and information in this Action constituting, containing or disclosing, in whole or in part, "Restricted Information, " as defined herein. This Order shall also apply to all other parties who appear in this action and whose counsel has received a copy of this Order.

2. As used in this Order, the following definitions shall apply:

a. The term "Restricted Information" refers to material/information of any type (including, but not limited to, communications and recordings contained in testimony, documents, discovery responses, e-mail, and all other media of expression) that has been designated "Confidential" and includes: (1) proprietary technical information and specifications; (2) trade secrets; (3) confidential know-how; (4) proprietary business and financial information; (5) social security numbers, personal financial information, tax returns, driver's license numbers, and other personal or private information, and (6) any other information the disclosure of which is likely to have the effect of causing substantial harm to the competitive position of the entity from which the information is obtained or of a third-party not a party to this Action. The parties will use reasonable care to avoid designating as "Restricted Information" any documents or information that (i) is in the public domain; or (ii) does not fall into any of the items (1) through (6) of this subparagraph. The fact that information is designated "Restricted Information" by a party does not constitute a waiver, concession, or admission by any other party that the information has been appropriately designated.

b. The term "Designating Party" refers to the party that has produced material/information containing Restricted Information. (In the case of materials produced by a third party, the term "Designating Party" refers to the party or non-party that has designated as "Restricted Information" the material/information that has been produced by the third party.)

c. The term "Receiving Party" refers to the party or parties, and/or their counsel, to which material/information containing Restricted Information has been produced.

3. All material/information produced in this litigation, through discovery, trial or otherwise, and designated by the Designating Party as "Restricted Information, " shall be subject to the non-disclosure provisions of this Order. In addition, any party may designate places or things subject to a discovery request for inspection or production as Restricted Information by informing counsel for the inspecting party in writing, prior to such inspection, that such information shall be deemed Restricted Information subject to this Order.

4. Except as may be otherwise provided by this Order or by further order of the Court, access to Restricted Information shall be limited to: (1) the Court and its officers; (2) mediators and/or arbitrators who may be engaged by the parties; (3) court reporters and/or videographers at depositions, hearings or other proceedings in this litigation; (4) attorneys of record in this litigation and in-house counsel for the parties, including the secretarial, legal assistant and office staffs of such attorneys, including outside vendors performing administrative or technical support tasks; (5) persons engaged by attorneys of record in this litigation to assist them in the preparation of this litigation, including independent experts and consultants and their employees retained for purposes of this litigation, with disclosure only permitted to the extent necessary to perform such work, provided further that such person shall first execute the Acknowledgement attached to this Order as Exhibit A; (6) the parties or employees of any party who are providing assistance to counsel in this litigation; and (7) non-expert witnesses used by any party in the action (collectively, the "Approved Persons"). Approved Persons having access to Restricted Information shall not disclose such Restricted Information to any person not bound by this Order and shall not use such material/information for any purpose other than for purposes of this litigation.

5. All Restricted Information produced or exchanged in the course of this Action shall be used solely for the purpose of preparing for and conducting this Action, including trial and appeal, if any, and shall not be used in any other civil action or for any other purpose whatsoever, including, but not limited to, any business purpose, except as may be ordered by this Court or where there is an express written agreement between the parties to the contrary.

6. No party and no other person granted access to Restricted Information under this Order shall disclose Restricted Information, or any material/information therefrom, except as provided in this Order.

7. Notwithstanding the foregoing, this Order do not restrict the right of the Designating Party to make such use or disclosure of its own documents or material that have been designated as Restricted Information as it otherwise is entitled to make. In addition, a Designating Party does not waive the classification of its own material/information as Restricted ...


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