DANIEL S. GLASS, Bar No. 140819 Sacramento, CA, Attorneys for Plaintiff DANIELA ROBINSON.
SEDGWICK LLP, REBECCA A. HULL, Bar No. 99802 MARK J. HANCOCK, Bar No. 160662 San Francisco, CA, Attorneys for Defendant METROPOLITAN LIFE INSURANCE COMPANY.
STIPULATED PROTECTIVE ORDER
JOHN A. MENDEZ, District Judge.
Subject to the approval of this Court, the parties hereby stipulate to the following protective order:
1. Purposes and Limitations
Discovery proceedings in this action may involve the production and disclosure of trade secrets or other confidential and proprietary commercial or financial information of MetLife for which protection from public disclosure and from use for any purpose other than prosecuting or defending this litigation may be warranted. The parties acknowledge that this Order does not confer blanket protections on all 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 applicable legal principles. The parties further acknowledge, as set forth in Section 8 below, that this Stipulated Protective Order does not entitle them to file confidential information under seal; Local Rule 141 sets forth the procedures to be followed when a party seeks permission from the Court to file material under seal.
For purposes of this Order, the following terms shall have the meanings set forth below:
2.1. "Challenging Party" shall mean and refer to a Party that challenges a designation of information under this Order;
2.2. "Confidential Information" shall mean information that qualifies for protection under Federal Rule of Civil Procedure 26(c);
2.3. "Designating Party" shall mean and refer to a Party that designates information that it produces in responses to discovery as "CONFIDENTIAL";
2.4. "Discovery Material" shall mean all information, regardless of the medium or manner in which it is generated, stored, or maintained (including, among other things, testimony and transcripts), that are produced or generated in responses to discovery in this action;
2.5. "Expert" shall mean and refer to 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;
2.6. "Party" shall mean and refer to any party to this action, including all of its officers, directors, employees, consultants, attorneys, affiliates and subsidiaries (and their support staffs);
2.7. "Producing Party" shall mean and refer to a Party that produces Discovery Material in this action;
2.8. "Professional Vendors" shall mean and refer to 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;
2.9. "Protected Material" means any Discovery Material that is designated as "CONFIDENTIAL";
2.10. "Receiving Party" means a Party that receives Discovery Material ...