United States District Court, C.D. California
EVOX PRODUCTIONS, LLC, a Delaware limited liability company, Plaintiff,
GABRIELS TECHNOLOGY SOLUTIONS, INC., a New York corporation, MICHAEL GABRIEL, an individual, and DOES 1 through 10, inclusive, Defendants.
[PROPOSED]ORDER FOR ENTRY OF A PROTECTIVE ORDER GOVERNING DISCLOSURE AND USE OF PLAINTIFF'S QUICKBOOKS FILE
RALPH ZAREFSKY, District Judge.
The Court, having read and considered the Joint Stipulation for Entry of a Protective Order filed by the parties, and good cause appearing therefore, IT IS HEREBY ORDERED that the terms and conditions of this Protective Order are as follows:
DEFINITIONS AND RULES
1. As used in this Protective Order, these terms have the following meanings:
a. "Highly Confidential Materials" are Plaintiff's Quickbooks;
b. "Written Assurance" means an executed document in the form attached as Exhibit A;
2. Plaintiff's Quickbooks constitute or contain non-public information that is entitled to protection under 26(c)(1)(G) of the Federal Rules of Civil Procedure and that is extremely sensitive financial information about Plaintiff's customers, vendors, revenue sources from customers and generally a financial roadmap to Plaintiff's business, the disclosure of which to another Party or non-party would create a substantial risk of serious injury or competitive harm that could not be avoided by less restrictive means. Plaintiff's Quickbooks will be designated and treated as "Highly Confidential- Attorney's Eyes Only" pursuant to this Protective Order.
3. All Highly Confidential Material will be used solely for the purpose of this action and no person receiving such documents, or information contained in such documents may, directly or indirectly, transfer, disclose, or communicate in any way the contents of the documents or information therein to any person other than those specified in paragraph 4 and 5.
4. Access to any Highly Confidential Materials is limited to:
a. the Court, its officers and jurors;
b. Outside counsel and their office associates, legal assistants, and stenographic and clerical employees;
c. persons shown on the face of the document to have authored ...