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Ecology Auto Parts, Inc. v. Ace American Insurance Co.

United States District Court, C.D. California

May 10, 2017

ECOLOGY AUTO PARTS, INC., Plaintiff,
v.
ACE AMERICAN INSURANCE COMPANY; ACE USA; and DOES 1 through 50, inclusive, Defendants.

          MICHAEL R. DAVISSON, ANDREA J. GIOVANNANE ATTORNEYS FOR DEFENDANTS ACE AMERICAN INSURANCE COMPANY

          [PROPOSED] PROTECTIVE ORDER GOVERNING CONFIDENTIAL INFORMATION

          Charles F. Eick Magistrate Judge

         Having reviewed the Joint Stipulation for Protective Order entered into between plaintiff, Ecology Auto Parts, Inc., and defendant, ACE American Insurance Company (collectively, the "Parties") in the above-caption litigation pending before this Court (the "Litigation"), this Court issues the following Protective Order Governing Confidential Information:

         1. This Stipulation for a Protective Order governs the use of all produced documents, responses to interrogatories and requests for admissions, deposition transcripts, and any other information, documents, objects or things, as well as any and all copies, abstracts, digests, notes, and summaries thereof, that have been or will be produced by any party or third-party (the "Producing Party") in this Litigation pursuant to the Federal Rules of Civil Procedure. These materials are collectively referred to hereinafter as the "Discovery Material."

         2. Any Discovery Material produced by any party or third-party as part of discovery in this Litigation may be designated by the Producing Party as "CONFIDENTIAL" which the Producing Party believes in good faith constitutes, contains, reflects or discloses confidential, non-public research and analysis, development or commercial or personal information or Discovery Material protected by the attorney-client and/or work-product privileges, or other information for which a good faith claim of need of protection from disclosure can be made under applicable law (the "Confidential Material").

         3. Any Discovery Material that is produced during this Litigation voluntarily, in response to a discovery request, or pursuant to a Court Order, in oral, written, or other form, including, but not limited to, transcripts, exhibits, answers to interrogatories, as well as any physical object, recording, electronic file, or other thing, that is asserted by the Producing Party to contain or constitute Confidential Material, shall be so designated by the Producing Party as follows:

a. Documents and Physical Items: If Confidential Material is contained in a document or other physical item, such documents and physical items shall be clearly and prominently marked on their face with the appropriate legend: "CONFIDENTIAL". When an item (such as a disk) containing more than one electronic file is produced, each electronic file on that disk that is confidential should be branded with the legend "CONFIDENTIAL" and have "CONFIDENTIAL" in the file name of each file designated as such.
b. Transcripts: Deposition or other pretrial testimony may be designated as "Confidential" by (i) a statement on the record, by counsel, at the time of such disclosure, or (ii) written notice sent to all counsel of record for the parties within fifteen (15) business days after receipt of the transcript of the deposition or other pretrial testimony unless the parties agree to an extension of this time period for designation. Notwithstanding any provision of this subsection, Discovery Material used or referenced during a deposition or other pretrial testimony shall maintain any confidentiality designation accorded such material hereunder regardless of the designation of any part of the transcript.
c. Information in Other Forms: All Confidential Material not reduced to documentary, tangible, or physical forms or that cannot be conveniently designated shall be designated by the Producing Party by notifying all parties of the appropriate designation in writing.

         4. In the absence of written permission from the Producing Party or court Order, Discovery Material designated as "CONFIDENTIAL" shall not be disclosed to any person other than the following individuals, who are each deemed a "Qualified Person" under this Paragraph:

a. counsel of record for parties to this Litigation and their support staff, including paralegals and clerical assistants;
b. opposing parties and their representatives, officers, agents, and/or employees who are directly involved in, and whose access to such Discovery Material is reasonably required for, the management, prosecution, defense, or settlement of this Litigation or the supervision of counsel of record;
c. non-party witnesses who are called to be deposed during discovery or trial, whether willingly or under subpoena issued by a court of ...

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