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Bona Fide Conglomerate, Inc. v. Sourceamerica

United States District Court, S.D. California

April 14, 2017

BONA FIDE CONGLOMERATE, INC., Plaintiff,
v.
SOURCEAMERICA, et al., Defendants. AND RELATED COUNTER-CLAIMS

          PROTECTIVE ORDER

          Hon. Andrew G. Schopler United States Magistrate Judge

         The Court recognizes that the parties to this action may be required to produce or disclose documents and information through discovery that is normally kept confidential. The parties have agreed to be bound by the terms of this Protective Order Regarding Confidential Information (“Protective Order”) in this action.

         The documents and information to be exchanged throughout the course of the litigation between the parties may contain sensitive and confidential financial and business information and other sensitive, confidential, proprietary, personal, or trade secret information, meriting legal protection from disclosure under Federal Rule of Civil Procedure 26(c)(1)(G) and other applicable statutory and common law. The purpose of this Protective Order is to protect the confidentiality of such materials as much as practical during the litigation. THEREFORE:

         1. DEFINITIONS.

         The following definitions shall apply to this Protective Order:

         a. The “Action” shall mean and refer to the above-captioned matter and to all actions now or later consolidated with the Action, and any appeal from the Action or from any other action consolidated: any time under the above-captioned matter, through final judgment.

         b. “Materials” shall include, but shall not be limited to: documents; correspondence; memoranda; bulletins; blueprints; specifications; customer lists or other material that identify customers or potential customers; price lists or schedules or other matter identifying pricing; minutes; telegrams; letters; statements; cancelled checks; contracts; invoices; drafts; books of account; worksheets; notes of conversations; desk diaries; appointment books; expense accounts; recordings; photographs; motion pictures; compilations from which information can be obtained and translated into reasonably usable form through detection devices; sketches; drawings; notes (including laboratory notebooks and records); reports; instructions; disclosures; other writings; models and prototypes and other physical objects.

         c. “Confidential Document” shall mean any Materials that any Designating Party (as defined below) designates as “Confidential” or “Confidential - For Counsel Only” in the manner set forth in this Protective Order; provided, however, that by agreeing to this Protective Order, no party waives the right to challenge any other party's designation of any Materials as “Confidential” or “Confidential - For Counsel Only.”

         d. “Confidential Information” shall mean any information not made available to the general public that concerns or relates to trade secret, business, financial, and/or personal information.

         e. “Designating Party” shall mean any party in this Action designating information or Material as “Confidential” or “Confidential - For Counsel Only.”

         f. “Receiving Party” shall mean any party in this Action receiving Confidential Documents or Confidential Information of a Designating Party.

         g. “Legend” as used herein shall mean a stamp or similar insignia stating “Confidential” or “Confidential - For Counsel Only, ” or other appropriate term or terms identifying the level of confidentiality of the Materials.

         h. When reference is made in this Protective Order to any document, the singular shall include the plural, and plural shall include the singular.

         2. DESIGNATION OF DOCUMENTS

         a. Each party to this litigation that produces or discloses any Materials, answers to interrogatories, responses to requests for admission, trial testimony, deposition testimony, and transcripts of trial testimony and depositions, or information that the producing party believes should be subject to this Protective Order may designate the same as “Confidential” or “Confidential - For Counsel Only.” b. The Designating Party may designate a document as “Confidential” or “Confidential - For Counsel Only” by affixing the appropriate Legend to all copies of the document at the time of production. Except as provided herein, the Designating Party must make document designations at the time of production or within fourteen (14) days of the entry of this Protective Order, whichever is later.

         c. A party may designate as “Confidential” or “Confidential - For Counsel Only” a document produced by someone else by informing in writing all parties of the control number of such document within seven (7) days of that party's receipt of the document or within fourteen (14) of the entry of this Protective Order, whichever is later.

         d. All parties receiving written notice of such designation shall affix the appropriate Legend to all pages of any copy or copies of such document in their possession.

         e. Any party may designate a deposition or hearing transcript (or any portion thereof or exhibit thereto) as “Confidential” or ...


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