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S.H. v. CVS Pharmacy, Inc.

United States District Court, C.D. California, Southern Division

May 24, 2017

S.H., a minor, by and through her Guardian ad Litem SHANNON AMBUEHL, and S.H., a minor, by and through her Guardian ad Litem TANJA ROSENBACH, Plaintiffs,
v.
CVS PHARMACY, INC., a California Corporation, CVS PHARMACY, INC., a Rhode Island Corporation, and DOES 1 through 30, inclusive, Defendants.

         [Removal from Superior Court of California, Orange County Case NO. 30-2017-00899953-CU-MM-CJC]

          Dennis K. Ames, Esq., State Bar# 81460 Marissa A. Warren, Esq., State Bar#: 249583 LA FOLLETTE, JOHNSON, DEHAAS, FESLER & AMES Attorneys for Defendants, GARFIELD BEACH CVS, LLC., erroneously sued and served herein as CVS PHARMACY, INC., a California Corporation, and CVS PHARMACY, INC., a Rhode Island Corporation

          ORDER RE STIPULATION FOR PROTECTIVE ORDER

          JAY C. GANDHI, MAGISTRATE JUDGE

         IT IS HEREBY ORDERED that pursuant to the stipulation of the parties for an order pursuant to Fed. R.Civ. P. 26(c) that confidential information be disclosed only in designated ways:

         1. As used in the Protective Order, these terms have the following meanings: "Attorneys" means counsel of record;

"Confidential" documents are documents designated pursuant to paragraph 2; "Documents" are all materials within the scope of Fed.R.Civ.P. 34; "Outside Vendors" means messenger, copy, coding, and other clerical-services vendors not employed by a party or its Attorneys; and "
Written Assurance" means an executed document in the form attached as Exhibit A.

         2. A Party may designate a document "Confidential", to protect information within the scope of Fed.R.Civ.P. 26(c).

         3. All Confidential documents, along with the information contained in the documents, shall be used solely for the purpose of this action, and no person receiving such documents shall, directly or indirectly, use, transfer, disclose, or communicate in any way the documents or their contents to any person other than those specified in paragraph. Any other use is prohibited.

         4. Access to any Confidential document shall be limited to:

(a) the Court and its staff;
(b) Attorneys, their law firms, and their Outside Vendors;
(c) persons shown on the face of the document to have authored ...

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