Matthew J. Faust State Bar No. 254145, Melissa N. Engle State Bar No. 272741, Frederick W. Gaston State Bar No. 231179, GASTON & GASTON, A PROFESSIONAL LAW CORPORATION, San Diego, California, Attorneys for Plaintiff, TRITON ENGINEERING.
JAMES J. YUKEVICH (SBN 159896), STEVEN S. VAHIDI (SBN 283951, YUKEVICH CAVANAUGH, Los Angeles, CA, Attorneys for Defendants. CRANE CO and ELDEC CORPORATION.
STIPULATED PROTECTIVE ORDER
JOHN E. McDERMOTT, Magistrate Judge.
Pursuant to Federal Rule of Civil Procedure 26(c), and in consideration of the mutual covenants contained herein, the undersigned counsel for the parties hereby stipulate as follows, and it is hereby ordered:
1. In connection with this Action, any party may designate any documents, electronically stored information, materials, things, discovery materials, materials filed with this Court, testimony, or other information derived therefrom, as "CONFIDENTIAL" pursuant to the terms of this Stipulated Protective Order ("Order"). Either the producing or receiving party may designate as "CONFIDENTIAL" any material or information that such party reasonably believes in good faith is subject to confidential protection under the law, including but not limited to Fed.R.Civ.P. 26(c) or other applicable statutory or common law, including trade secrets; confidential research, development, or other commercial information; other proprietary or sensitive business information; or personal, medical, or personnel information. Any materials designated in accordance with this paragraph shall hereinafter be referred to as "Confidential Materials."
2. A producing party may designate Confidential Materials by stamping the materials with the legend "CONFIDENTIAL." Stamping "CONFIDENTIAL" on the cover of any multi-page document shall designate all pages of the document as "CONFIDENTIAL, " unless otherwise indicated by the designating party. Any confidential material produced on disks or other computer-related media may be designated as Confidential by labeling the media as "CONFIDENTIAL."
3. Confidential Materials shall be maintained in strict confidence by all persons permitted access to such Confidential Materials pursuant to the terms of this Order. However, the mere fact that any document or information is designated as "CONFIDENTIAL" pursuant to this Order shall not signify that any such document or information is in fact confidential or be construed as an admission that such document or information is confidential.
4. Deposition transcripts, or portions thereof, may be designated as "CONFIDENTIAL" by (a) making a statement to that effect on the record at the deposition, or (b) counsel's written designation of certain pages of the transcript as "CONFIDENTIAL" within fourteen (14) days of the receipt of the transcript by attorneys for all parties.
5. Confidential Materials marked as "CONFIDENTIAL" shall not be used for any purpose except in connection with this litigation, and shall not be delivered or disclosed, in whole or in part, to any person except:
a. the Court and its officers (including court reporters);
b. counsel of record for the parties and their staff, as well as employees of third party vendors engaged to provide litigation support services;
c. the parties, and any current employees of the parties who are involved in the prosecution, defense, and/or appeal of this action;
d. the parties' independent experts retained in connection with ...