LILIANA IBARRA, et al. Plaintiff,
INLAND COUNTIES REGIONAL CENTER, INC. and DOES 1 THROUGH 50, inclusive, Defendant.
LEWIS BRISBOIS BISGAARD & SMITH LLP JEFFREY S. RANEN, SB# 224285 BRENDAN T. SAPIEN, SB# 274247 Los Angeles, California Attorneys for Defendant Inland Counties Regional Center
Todd Boley, Esq. Attorneys for Plaintiff
STIPULATION FOR PROTECTIVE ORDER AND ORDER THEREON
OSWALD PARADA, Magistrate Judge.
1. PURPOSES AND LIMITATIONS
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 may 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 from public disclosure and use extends only to the limited information or items that are entitled to confidential treatment under the applicable legal principles. The parties further acknowledge, as set forth in Section 14.3, below, that this Stipulated Protective Order does not entitle them to file confidential information under seal; Civil Local Rule 79-5 sets forth the procedures that must be followed and the standards that will be applied when a party seeks permission from the court to file material under seal.
2.1 Challenging Party: a Party or Non-Party that challenges the designation of information or items under this Order.
2.2 "CONFIDENTIAL" Information or Items: information (regardless of how it is generated, stored or maintained) or tangible things that qualify for protection under Federal Rule of Civil Procedure 26(c).
2.3 Counsel (without qualifier): Outside Counsel of Record and House Counsel (as well as their support staff).
2.4 Designating Party: a Party or Non-Party that designates information or items that it produces in disclosures or in responses to discovery as "CONFIDENTIAL."
2.5 Disclosure or Discovery Material: all items or information, regardless of the medium or manner in which it is generated, stored, or maintained (including, among other things, testimony, transcripts, and tangible things), that are produced or generated in disclosures or responses to discovery in this matter.
2.6 Expert: a person with specialized knowledge or experience in a matter pertinent to the litigation who has been retained by a Party or its counsel to serve as an expert witness or as a consultant in this action.
2.7 House Counsel: attorneys who are employees of a party to this action. House Counsel does not include Outside Counsel of Record or any other outside counsel.
2.8 Non-Party: any natural person, partnership, corporation, association, or other legal entity not named as a Party to this action.
2.9 Outside Counsel of Record: attorneys who are not employees of a party to this action but are retained to represent or advise a party to this action and have appeared in this action on behalf of that party or are affiliated with a law firm which has appeared on behalf of that party.
2.10 Party: any party to this action, including all of its officers, directors, employees, consultants, retained experts, and Outside Counsel of Record (and their support staffs).
2.11 Producing Party: a Party or Non-Party that produces Disclosure or Discovery Material in this action.
2.12 Professional Vendors: persons or entities that provide litigation support services (e.g., photocopying, videotaping, translating, preparing exhibits or demonstrations, and organizing, storing, or retrieving data in any form or medium) and their employees and subcontractors.
2.14 Receiving Party: a Party that receives Disclosure or Discovery Material from a Producing Party.
3. PROTECTED MATERIAL Protected Material, for the purposes of this Stipulation shall be defined as:
a) Documents disclosing the name, address, telephone number, Unique Client Identification ("UCI") number or any other date identifying or relating to an individual consumer of services under the Lanterman Development Disabilities Services Act, California Welfare and Institutions Code §§ 4500, et seq.;
b) Any other Document made confidential pursuant to California Welfare and Institutions Code § 4515; and
c) Any Documents disclosing the name, address, telephone number, UCI number or any other date identifying or relating to an individual consumer of services, containing medical information implicating consumers' privacy rights and personal health information which is protected by ...