[PROPOSED] PROTECTIVE ORDER ON STIPULATION OF THE PARTIES
RALPH ZAREFSKY, Magistrate Judge.
Pursuant to the Stipulation of the Parties, by and through their counsel of record, Plaintiff ARMIDA RODRIGUEZ ("Plaintiff") and Defendants BURLINGTON COAT FACTORY WAREHOUSE CORPORATION and BURLINGTON COAT FACTORY OF CALIFORNIA LLC (collectively, "Burlington" or "Defendants"), this Court makes the following Order:
1. Proceedings and Information Governed. This Order will govern the video surveillance footage and documents produced by Burlington in this action. The information protected includes, but is not limited to, information produced in connection with Federal Rule of Civil Procedure 26, information contained in responses to demands for identification and production of documents or other things; responses to special interrogatories; deposition testimony and exhibits, including any documents or other information or materials that may be produced prior, or subsequent, to any depositions; and all copies, extracts, summaries, compilations, and portions of the foregoing.
2. "Confidential" Information or Material Defined. For purposes of this Order, "Confidential" information or material will mean all video surveillance footage, information, documents, or material that:
a. Is produced for or disclosed to a receiving party (Plaintiff or Defendants); and
b. Is among the documents and information Defendants have agreed to produce to Plaintiff; and
c. contains private and confidential information of third parties or proprietary information of Burlington.
3. Designation of "Confidential" Information or Material. All video surveillance footage and documents, including but not limited to the putative Class List, produced by Burlington will be designated as "Confidential" with a stamp or other inscription on the video disc and documents that states: "Confidential" or "Confidential Pursuant to Protective Order."
4. Party's Own Information. The restrictions on the use of "Confidential" information or material established by this Order apply only to the use by a party of "Confidential" information or material received from another party to this action, or from a non-party to this action, and shall not apply to the use by a party of her/its own information.
5. Persons Authorized to Receive Confidential Information and Material. For purposes of this Order, the term "qualified recipient" of information and material that has been designated pursuant to the terms of the Stipulation of the Parties, and in compliance with this Order shall mean:
(a) The parties to this action, including officers, directors, and other employees of the party to whom disclosure of confidential information is deemed necessary by that party for purposes of this action only;
(b) The attorneys of record in this action, attorneys employed in-house by or on behalf of the parties, any attorneys retained by the parties in this action to consult on the litigation, their respective partners, associates, clerks, legal assistants, secretaries, and stenographic and support personnel, and such other persons retained by such attorneys to provide litigation support services in this action including outside consultants or experts;
(c) This Court and its personnel and jury members, and any persons to whom the Court in this action orders that disclosures may be made.
(d) During their depositions, witnesses in this action to whom disclosure is reasonably necessary and only if the witnesses agree in writing ...