Bryan C. Altman (State Bar No. 122976), Joel E. Elkins (State Bar No. 256020), THE ALTMAN LAW GROUP, Los Angeles, California, Attorneys for Plaintiff ORIT ARFA.
Cynthia L. Filla (SBN 184638), Jennifer B. Hodur (SBN 211948), Danny Yadidsion (SBN 260282), JACKSON LEWIS P.C., Los Angeles, California, Gregory S. Glazer, Esq., HIRSCHFELD KRAEMER LLP, Santa Monica, CA, Attorneys for Defendants, ZIONIST ORGANIZATION OF AMERICA and MORTON KLEIN.
PROTECTIVE ORDER PRECLUDING DISCLOSURE OF CONFIDENTIAL INFORMATION
SUZANNE H. SEGAL, District Judge.
Based upon the Stipulation and [Proposed] Protective Order Precluding Disclosure of Confidential Information submitted by the parties, and for good cause shown:
GOOD CAUSE STATEMENT. Good cause exists for the Court to grant the Parties' stipulation and issue a protective order in the above-captioned action (the "Litigation"), so as to permit the Parties to engage in the discovery process without improperly disclosing or divulging confidential, sensitive, and/or private information of the Parties, or any of them, and to prevent the dissemination of constitutionally-protected private information of third-party non-litigants.
1. This stipulated confidentiality agreement and protective order ("Protective Order") shall govern the production, use, and handling of confidential documents and information produced by any Party in any form in the Litigation (collectively, "Material"). Any Party or non-party may designate as "Confidential" any documents, information, or other things that contain confidential information not previously made available to the public, which any Party or non-party contends should be protected from disclosure pursuant to this Protective Order.
2. "Confidential Information" means any document, file, portion(s) of file(s), transcribed testimony, or response(s) to discovery request(s), including any extract, abstract, chart, summary, note, or copy made therefrom - not made available to the public - and designated by one of the Parties in the manner provided in Paragraphs 3-5 below, containing:
a. Donor information, including identifying information of prospective and actual donors to the ZOA (including names, Social Security numbers, addresses, telephone numbers, email addresses, and bank account information), donation or contribution amounts, and communications between donor(s) and the ZOA (including any and all of its current and former employees and board members) regarding specific donations or contributions of current and former prospective and actual donors to the ZOA;
b. Personnel information, including identifying information (including Social Security numbers, addresses, telephone numbers, and email addresses), personnel records, compensation history, performance reviews, and disciplinary action of the ZOA's current and former employees;
c. Board member information, including identifying information (including Social Security numbers, addresses, telephone numbers, and email addresses) and contribution amounts of members of the ZOA's board of directors;
d. Commercially sensitive and/or confidential materials related to the ZOA, its donors and prospective donors, and its fundraising efforts and strategies;
e. Information regarding Plaintiff's treatment with a therapist.
3. Confidential Designation of Material.
Any Party or non-party producing or filing a document or thing in the Litigation may designate it at the time of its production or filing as subject to this Protective Order by designating the Material as Confidential by typing or stamping on each page so designated (without obscuring or defacing the Material) "Confidential, " "Confidential Subject to Protective Order, " or words of similar import ("Confidential Information"). The Parties agree to exercise good faith in evaluating whether materials should receive any Confidential Information designation pursuant to this Protective Order.
The Parties may designate documents previously produced in the Litigation as "Confidential" by providing written notice to the other party of the designation and identifying the documents that the Party wishes to designate as "Confidential" by Bates numbers.
4. Designation of Deposition Testimony as Confidential.
Any Party, or any third party as to testimony given by the third party at that third party's deposition, may designate deposition testimony, including formally-marked exhibits to deposition transcripts, as "Confidential" by stating on the record at the deposition, or in writing within thirty (30) days after the receipt of the deposition transcript, that specified testimony is confidential. During the thirty (30) day period immediately following any ...