United States District Court, C.D. California, Southern Division
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,
CVS PHARMACY, INC., a California Corporation, CVS PHARMACY, INC., a Rhode Island Corporation, and DOES 1 through 30, inclusive, Defendants.
from Superior Court of California, Orange County Case NO.
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
ORDER RE STIPULATION FOR PROTECTIVE ORDER
GANDHI, MAGISTRATE JUDGE
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
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.
Party may designate a document "Confidential", to
protect information within the scope of Fed.R.Civ.P. 26(c).
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
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