SEYFARTH SHAW LLP, Laura Wilson Shelby (SBN 151870), Jamie C. Chanin (SBN 244659), Los Angeles, California, Attorneys for Defendant, COSTCO WHOLESALE CORPORATION.
RICHARD T. COLLINS, ESQ. (SBN 166577), DAVID B. EZRA, ESQ. (SBN 149779), BERGER KAHN, A Law Corporation, Irvine, California, Attorneys for Plaintiff SHAD THOMAS.
STIPULATED PROTECTIVE ORDER
JEAN P. ROSENBLUTH, Magistrate Judge.
Plaintiff and Cross-Defendant Shad Thomas ("Plaintiff') and Defendant and Cross-Complainant Costco Wholesale Corporation ("Defendant), by and through their respective counsel, hereby submit this Proposed Stipulated Protective Order:
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 (or any future civil litigation between Costco and Plaintiff, specifically) would 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 extends only to the limited information or items that are entitled under the applicable legal principles to treatment as confidential.
2.1 Party: any party to this action, including all of its officers, directors, employees, consultants, retained experts, and outside counsel (and their support staff).
2.2 Disclosure or Discovery Material: all items or information, regardless of the medium or manner generated, stored, or maintained (including, among other things, testimony, transcripts, or tangible things) that are produced or generated in disclosures or responses to discovery in this matter, after execution of this stipulation.
2.3 "CONFIDENTIAL" Information or Items: information (regardless of how generated, stored or maintained) or tangible things that qualify for protection under standards developed under F.R.Civ.P. 26(c).
2.4 Receiving Party: a Party that receives Disclosure or Discovery Material from a Producing Party.
2.5 Producing Party: a Party or non-party that produces Disclosure or Discovery Material in this action.
2.6 Designating Party: a Party or non-party that designates information or items that it produces in disclosures or in responses to discovery as "CONFIDENTIAL."
2.7 Protected Material: any Disclosure or Discovery Material that is designated as "CONFIDENTIAL."
2.8 Outside Counsel: attorneys who are not employees of a Party but who are retained to represent or advise a Party in this action.
2.9 House Counsel: attorneys who are employees of a Party.
2.10 Counsel: Outside Counsel and House Counsel (as well as their support staffs).
2.11 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 and who is not a past or a current employee of a Party or of a competitor of a Party's and who, at the time of retention, is not anticipated to become an employee of a Party or a competitor of a Party's. This definition includes a professional jury or trial consultant retained in connection with this litigation.
2.12 Professional Vendors: persons or entities that provide litigation support services (e.g., photocopying; videotaping; translating; preparing exhibits or demonstrations; organizing, storing, retrieving data in any ...