United States District Court, C.D. California
ANTIAGING INSTITUTE OF CALIFORNIA, INC., a California corporation, Plaintiff,
v.
SOLONOVA, LLC, a California limited liability company, et al., Defendants.
HON.
ANDRÉ BIROTTE, JR. JUDGE
PROTECTIVE ORDER
FREDERICK F. MUMM UNITED STATES MAGISTRATE JUDGE
PROTECTIVE
ORDER
The
Court, finding that a protective order is proper and
desirable in the circumstances of this case, and good cause
appearing therefore, pursuant to Rule 26(c) of the Federal
Rules of Civil Procedure, makes the following Order for the
benefit of all parties and witnesses to govern the course of
the proceedings in this case:
1.
DEFINITIONS.
1.1
Party: any party to this action, including all of
its officers, directors, employees, consultants, retained
experts, and outside counsel (and their support staff).
1.2
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.
1.3
“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).
1.4
“Highly Confidential -- Outside Counsel Only”
Information or Items: extremely sensitive
“Confidential Information or Items” whose
disclosure to another Party or nonparty would create a
substantial risk of serious injury that could not be avoided
by less restrictive means.
1.5
Receiving Party: a Party that receives Disclosure or
Discovery Material from a Producing Party.
1.6
Producing Party: a Party or non-party that produces
Disclosure or Discovery Material in this action.
1.7.
Designating Party: a Party or non-party that
designates information or items that it produces in
disclosures or in responses to discovery as
“Confidential” or “Highly Confidential --
Outside Counsel Only.”
1.8
Protected Material: any Disclosure or Discovery
Material that is designated as “Confidential” or
as “Highly Confidential -- Outside Counsel Only.”
1.9
Outside Counsel: Attorneys (as well as their support
staffs) who are retained to represent or advise a Party in
this action.
1.10
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. This definition
includes a professional jury or trial consultant retained in
connection with this litigation. The expert witness or
consultant may not be a past or a current employee of the
Party (including any affiliates or related entities) adverse
to the Party engaging the expert witness or consultant, or
someone who at the time of retention is anticipated to become
an employee of the Party (including any affiliates or related
entities) adverse to the Party engaging the expert witness or
consultant. Moreover, the expert witness or consultant may
not be a current employee or anticipated to become an
employee of any entity who is a competitor of the Party
adverse to the Party engaging the expert witness or
consultant.
1.11
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
form or medium; etc.) and their employees and subcontractors.
2.
SCOPE.
The
protections conferred by this Protective Order Governing
Discovery cover not only Protected Material (as defined
above), but also any information copied or extracted
therefrom, as well as all copies, excerpts, summaries, or
compilations thereof, plus testimony, conversations, or
presentations by parties or counsel to or in court or in
other settings that might reveal Protected Material. This
Protective Order Governing Discovery does not confer blanket
protections on all disclosures or responses to discovery. The
protection it affords extends only to the limited information
or items that are entitled under the applicable legal
principles to treatment as confidential.
3.
DURATION.
Even
after the termination of this litigation, the confidentiality
obligations imposed by this Order shall remain in effect
until a Designating Party agrees ...