United States District Court, C.D. California
Osric Brown, Neil Davenport, Phil Duncan, Marcia Frater, Sherri Frost, Elva Johnson, Todd Kennedy, Jessi Presten, Pamela Roark, Debbie Thompson, Harry Timuryan, Diana Vergini, and Lee Ward, individually, and on behalf of the general public, Plaintiffs,
Prospect Mortgage, LLC, Defendant.
Andrew M. Paley (SBN 149699), Los Angeles, CA. SEYFARTH SHAW LLP,
SEYFARTH SHAW LLP, Brandon R. McKelvey (SBN 217002), Timothy B. Nelson (SBN 235279), Sacramento, California. Attorneys for Defendants, PROSPECT MORTGAGE, LLC.
NICHOLS KASTER, LLP, Matthew C. Helland (SBN 250451), Adam W. Hansen (SBN 264241), San Francisco, CA. Attorneys for Plaintiffs.
STIPULATION AND [PROPOSED] PROTECTIVE ORDER REGARDING DISCOVERY
CARLA WOEHRLE, Magistrate Judge.
In accordance with Federal Rule of Civil Procedure 26(c), and for good cause shown, IT IS HEREBY ORDERED:
1. This Protective Order shall apply to all information produced by the parties to this action during the course of discovery in this litigation, including document productions, interrogatory answers, responses to requests for admissions, depositions, and discovery materials otherwise produced or provided to the parties by non-parties pursuant to judicial procedures (collectively defined as "Litigation Materials").
2. In producing or disclosing Litigation Materials, any party may designate as "Confidential" any portion of any Litigation Materials that it believes, in good faith, constitutes or contains non-public, highly sensitive, private, confidential, trade secret information or proprietary information (collectively defined as "Confidential Materials").
3. In producing or disclosing Litigation Materials, any party may designate as "Highly Confidential Information - Attorneys' Eyes Only, " any Litigation Materials that are particularly sensitive and constitute or contain non-public, highly sensitive, private, confidential, trade secret information or proprietary information (collectively defined as "Highly Confidential Materials").
4. All Confidential Materials and Highly Confidential Materials made available in the course of the litigation of this case shall be used solely for the purposes of preparing for and conducting the litigation of this case and for no other purpose whatsoever. No Confidential Materials or Highly Confidential Materials may be used or disseminated except in accordance with the terms of this Protective Order.
5. The parties may designate Litigation Materials as "Confidential" or "Highly Confidential Information-Attorneys' Eyes Only" at or before production or disclosure by (a) stamping or otherwise writing the legend "CONFIDENTIAL" or "HIGHLY CONFIDENTIAL-ATTORNEYS' EYES ONLY" on the Litigation Materials or (b) by an alternative method acceptable to all parties. In the event that Litigation Materials that are not designated initially as confidential or highly confidential-attorneys' eyes only are later designated as such, they shall thereafter be treated as confidential or highly confidential-attorneys' eyes only Litigation Materials in accordance with this Protective Order.
6. Parties may designate depositions or other testimony as confidential or highly confidential-attorneys' eyes only by any one of the following means: (a) stating orally on the record that the information is confidential or highly confidential-attorneys' eyes only and the portions for which such designation is made, on the day that testimony is given; or (b) sending written notice designating information as confidential or highly confidential-attorneys' eyes only within fifteen days after receipt of a final transcript thereof. All information disclosed during a deposition shall be treated as if it were confidential unless and until the fifteen-day period set forth in this paragraph has expired without any written designation notice having been sent. Failure to designate depositions or other testimony as confidential or highly confidential-attorneys' eyes only within this fifteen-day period, however, does not preclude a party from doing so later in accordance with this order.
7. Litigation Materials designated "Confidential" and any copies thereof or information contained therein shall be maintained in confidence by the attorney of record to whom such Litigation Materials are produced or disclosed and such Litigation Materials and/or the information contained in such Litigation Materials shall be disclosed only to the following Qualified Persons:
(a) Parties to the litigation, including employees of parties to the extent deemed reasonably necessary by counsel for the party for assistance ...