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Sisyphus Touring, Inc. v. TMZ Productions, Inc.

United States District Court, C.D. California

June 17, 2016

SISYPHUS TOURING, INC., Plaintiff,
v.
TMZ PRODUCTIONS, INC., a California corporation; TMZ. com, a fictional entity of unknown form; EHM PRODUCTIONS, INC., a California corporation; WARNER BROS. ENTERTAINMENT, INC., a Delaware corporation; and DOES 1-10, inclusive, Defendants.

         DISCOVERY MATTER

          KING, HOLMES, PATERNO & SORIANO, LLP HOWARD E. KING, ESQ., STATE BAR NO. 77012 SETH MILLER, ESQ., STATE BAR NO. 175130, Attorneys for Plaintiff SISYPHUS TOURING, INC.

          PROTECTIVE ORDER

         Upon stipulation of the parties and consideration of the representations of the parties and the matters presented to the Court, the Court enters this Order to provide for protection of the respective parties' confidential, proprietary and financial information for purposes of discovery and pre-trial in this proceeding.

         1. Information Subject To The Protective Order:

         The parties seek protection for, including without limitation, confidential, proprietary, and/or financial information that has not been made public. Each of the parties hereto represents to the Court in regard only to its own respective confidential materials that the foregoing materials are and at all times have been maintained in confidence by each respective party, are not publicly available, and have not been disclosed to third parties except to the extent reasonably necessary for business purposes under circumstances where the confidentiality of the materials would be maintained; and that public disclosure of the foregoing materials, including to each respective party's competitors, could cause competitive injury and prejudice, or is information of a personal and confidential nature in which the affected person has a reasonable expectation of privacy. The foregoing is by way of example only and is not intended to limit and is without prejudice to: (a) the nature or scope of materials subject to protection hereunder, or the right of any party to challenge the scope of materials subject to protection; (b) any party's right to challenge any other party's confidentiality designation made hereunder with respect to any specific documents or information produced in discovery; or (c) any party's objections to producing any specific documents or information in discovery or otherwise in connection with this action.

         2. For the purposes of this Order, the words "document" and "documents" are used in the broadest possible sense and refer, without limitation, to documents as they are defined in Fed.R.Civ.P. 34(a)(1)(A) and 34(b)(2)(B).

         3. In connection with discovery proceedings in this action, the parties may designate any document, thing, material, testimony, or other information derived therefrom, as "Confidential" under the terms of this Protective Order. Confidential information is information which has not been made public and which concerns or relates to the matters described in Paragraph 1, above.

         4. By designating a document, thing, material, testimony or other information derived therefrom as "Confidential" under the terms of this Order, the party making the designation is certifying to the Court that there is a good faith basis in law and in fact for the designation within the meaning of Fed.R.Civ.P. 26(g).

         5. Confidential documents produced in physical format (including copies of physical documents produced in PDF, .tiff or other machine-readable format) shall be so designated by stamping copies of the document produced to a party with the legend "CONFIDENTIAL" or by cover letter designation identifying the page number(s) of the production that the party designates as Confidential. Stamping the legend "CONFIDENTIAL" on the cover of any multipage document shall designate all pages of the document as Confidential, unless otherwise indicated by the producing party. Responses to interrogatories or requests for admissions may be designated as "CONFIDENTIAL" by clearly labeling them as such on the cover or the responses or in the body of any individual response(s). Any Confidential electronically stored information produced on magnetic disks or other computer-related media may be designated as such by labeling each disk or analogous media "CONFIDENTIAL" when produced. Electronic or native documents or information shall be similarly labeled where practicable, and where not practicable, written notification by a producing party that it is producing materials designated as "CONFIDENTIAL" shall suffice for Confidential treatment as provided herein.

         6. Testimony taken at a deposition may be designated as Confidential by making a statement to that effect on the record at the deposition or, within 10 days of the preparation of the transcript of the deposition, identifying in writing the confidential portions of the transcript. Upon a party identifying the testimony as Confidential prior to preparation of the transcript, the court reporter shall prepare the transcript of the testimony in a separate binder designated as confidential. Testimony designated as confidential after the transcript is prepared shall be maintained as confidential, and counsel will be responsible for marking the copies of the transcript in their possession or under their control as confidential in accordance with the designation.

         7. Material designated as Confidential under this Protective Order, the information contained therein, and any summaries, copies, compilations, abstracts, or other documents derived in whole or in part from material designated as confidential (hereinafter "Confidential Material") shall be used by the receiving party only for the purpose of the prosecution, defense, or settlement of this action, including any appeals, and for no other purpose.

         8. Confidential Material produced pursuant to this Protective Order may be disclosed or made available only to the Court, to counsel for a party (including the paralegal, clerical, and secretarial staff employed by such counsel, and in-house counsel), and to the "qualified persons" designated below:

(a) a party, or an officer, director, employee, manager, or representative of a party deemed necessary by counsel to aid in the prosecution, defense, or settlement of this action;
(b) experts or consultants (together with their clerical staff) retained by such counsel to assist in the prosecution, ...

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