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Den-Mat Holdings, LLC v. CAO Group, Inc.

United States District Court, C.D. California

June 29, 2016

DEN-MAT HOLDINGS, LLC, Plaintiff,
v.
CAO GROUP, INC., Defendant.

          PERKINS COIE LLP LARA J. DUEPPEN, JOHN A. SQUIRES (PRO HAC VICE), JONATHAN M. JAMES (PRO HAC VICE), MICHAEL R OSTERHOFF (PRO HAC VICE) ATTORNEYS FOR PLAINTIFF DEN-MAT HOLDINGS, LLC

          TRASKBRITT, P.C. BY H. DICKSON BURTON (PRO HAC VICE), JEFFREY W SHIELDS ATTORNEYS FOR DEFENDANT/THIRD-PARTY PLAINTIFF CAO GROUP, INC.

          GIBSON, DUNN & CRUTCHER LLP BY: MICHELE L. MARYOTT WILLIAM C ROOKLIDGE KRISTA S DEBOER ATTORNEYS FOR THIRD-PARTY DEFENDANT DISCUS DENTAL, LLC

          DISCOVERY MATTER [PROPOSED] PROTECTIVE ORDER

          JOHN E. MCDERMOTT MAGISTRATE JUDGE

         This Order governs the handling of all information, documents, deposition testimony and exhibits, discovery answers and responses, and other written, recorded or graphic matter produced or provided in this lawsuit, formally or informally, which are designated as "CONFIDENTIAL" (hereinafter defined) pursuant to this Order. This Order also governs all notes, extracts, summaries or other information derived from information designated as "CONFIDENTIAL" and all pleadings, briefs, memoranda or other filings that quote or convey the substance of information designated as "CONFIDENTIAL" under the terms of this Order.

         THEREFORE, the undersigned having so stipulated, this Court, pursuant to Fed.R.Civ.P. 26(c), having determined that good cause exists to enter a Protective Order, HEREBY ORDERS that:

         1. For the purposes of this Order, the following definitions shall govern:

"CONFIDENTIAL" means the designation for product research and development, commercial, financial, marketing and sales, or personnel information that a party maintains in confidence and the public disclosure of which would potentially harm the party's business operations or reveal a party's private information;
"COUNSEL" means all attorneys of record in the above captioned case and any lawyers employed by their law firms in connection with this litigation, but does not include lawyers employed on behalf of third parties or witnesses;
"COURT PERSONNEL" means judges, clerks, or other members or employees of any court of competent jurisdiction over proceedings in or related to the litigation;
"DOCUMENT" shall have the same meaning as set forth by Rule 34(a)(1)(A) of the Federal Rules of Civil Procedure;
"EXPERT" means any person engaged by a party as a testifying or consulting expert witness; and
"SUPPORT PERSONNEL" means any clerical or support staff or other employee of COUNSEL or an EXPERT assisting with this litigation, specifically including (i) secretarial support staff, (ii) paralegal employees, (iii) any independent stenographer or videographer retained, to record and transcribe testimony in this action, (iv) litigation personnel or contract attorneys acting under the direction of COUNSEL; (v) any in-house or independent entity retained by COUNSEL for the purpose of data collection, processing, hosting, and production, and (vi) any in-house or independent entity retained or used for the purpose of making photocopies or other replications or duplications of material designated under this Order.

         2. A party may designate as "CONFIDENTIAL" any DOCUMENTS, information, and materials generated or produced in response to any discovery, including but not limited to DOCUMENTS, things, and responses to requests for documents and things, interrogatory answers, deposition testimony, answers to requests for admission, expert reports, and responses to other discovery demands, as well as any copies, ...


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