United States District Court, C.D. California, Southern Division
Gandhi U.S. Magistrate Judge.
light of the Stipulation of the parties filed herewith, and
good cause appearing therefore, IT IS HEREBY
ORDERED as follows:
party to this action, including all of its officers,
directors, employees, consultants, retained experts, and
Outside Counsel (and their support staff).
Disclosure or Discovery Material
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.
“Confidential Information” or Items
(regardless of how generated, stored or maintained) or
tangible things that contains or discloses trade secrets or
confidential research, development, commercial, financial or
proprietary information, or which contains or discloses
information protected by the right to privacy.
Information shall not include any document, information, or
other material that:
(i) is, at the time of disclosure, in the public domain by
publication or otherwise;
(ii) becomes at any time, through no act or failure to act on
the part of the Receiving Party, part of the public domain by
lawful publication or other lawful act;
(iii) is already in the possession of the Receiving Party at
the time of disclosure and was not acquired directly or
indirectly from the Producing Party; or
(iv) is made available to the Receiving Party by a third
party who obtained the same by legal means and without any
obligation of confidence to the party claiming its
that receives Disclosure or Discovery Material from a
or non-party that produces Disclosure or Discovery Material
in this action.
or non-party that designates information or items that it
produces in disclosures or in responses to discovery as
Disclosure or Discovery Material that is designated as
“Confidential.” H. Outside Counsel
Attorneys who are not employees of a Party but who are
retained to represent or advise a Party in this action.
who are employees of a Party.
Counsel (without qualifier)
Counsel and House Counsel (as well as their support staffs).
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. “Expert” also shall
mean an employee of a party who is retained as an expert in
this action. This ...