United States District Court, C.D. California, Western Division
Luiza Manuelian Sally Hosn Poole & Shaffrey, LLP Los Angeles, CA Attorneys for Defendant ITW FOOD EQUIPMENT GROUP LLC
Elizabeth B. Wright (admitted pro hac vice) Andrew H. Cox (admitted pro hac vice) Conor A. McLaughlin (admitted pro hac vice) Thompson Nine LLP Cleveland, OH Attorneys for Defendant ITW FOOD EQUIPMENT GROUP LLC
Frank J. D'Oro carl Kremer Wesierski & Zurek LLP Los Angeles, California Attorneys for Plaintiffs ADELA RAMIREZ and VALLARTA FOOD ENTERPRISES, INC.
Dennis W. Ryan Dennis W. Ryan, Inc. Woodland Hills, CA Attorney for Plaintiff ADELA RAMIREZ
STIPULATED SHARING AND NON-SHARING PROTECTIVE ORDER
ALICIA G. ROSENBERG, Magistrate Judge.
In order to preserve and maintain the confidentiality of certain confidential, commercial and/or proprietary documents and information produced or to be produced by ITW Food Equipment Group LLC ("ITW FBG") in this action, it is ordered that:
1. Documents to be produced by ITW FEG in this litigation that contain confidential, commercially sensitive and/or proprietary information shall hereafter be referred to as "Protected Documents." A document or portion of a document that ITW FEG determines in good faith to be a Protected Document may be designated as confidential by marking or placing the applicable notice "Subject to Non-Sharing Protective Order, " "Subject to Protective Order, " "Confidential, " or substantially similar language on media containing Protected Documents, on the document itself, or on a copy of the document, in such a way that it does not obscure the text or other content of the document.
2. As used in this Order, the term "documents" means all written material, videotapes and all other tangible items, produced in whatever format (e.g., hard copy, electronic, digital, etc.) and on whatever media (e.g., hard copy, videotape, computer diskette, CD-ROM, DVD, hard drive or otherwise).
3. Any document or any information designated as "Subject to Non-Sharing Protective Order, " "Subject to Protective Order, " "Confidential, " or substantially similar language in accordance with the provisions of this Order shall only be used, shown or disclosed as provided in this Order.
4. If a party disagrees with the "Protected" designation of any document, the party will so notify, ITW FEG in a written letter, identifying the challenged document(s) with specificity, including Bates number(s) where available. If the parties are unable to resolve the issue of confidentiality regarding the challenged document(s), ITW FEG will then timely apply to the Court to set a hearing for the purpose of establishing that the challenged document(s) is/are confidential. Any document so marked as "Protected" will continue to be treated as such pending determination by the Court as to its confidential status.
5. Protected Documents and any copies thereof received pursuant to paragraph 6 below shall be maintained confidential by the receiving party, his/her attorney, other representatives, and expert witnesses, and shall be used only for preparation for the trial of this matter, subject to the limitations set forth herein.
6. Protected Documents shall be disclosed only to "Qualified Persons." Qualified Persons are limited to:
a. Counsel of Record for the parties;
b. Non-technical and clerical staff employed by Counsel of Record and involved in the preparation ...