United States District Court, C.D. California, Western Division
J. Anderson, Esq., Cal. Bar No. 88891 LAW OFFICES OF PETER J.
ANDERSON A Professional Corporation Attorney for Defendant WB
ANDREW J. WISTRICH, UNITED STATES MAGISTRATE JUDGE
parties to this action anticipate that the conduct of this
matter may require disclosure of confidential information,
including trade secrets, research, development, commercial,
financial or strategic information, within the scope of
Federal Rule of Civil Procedure 26(c). Accordingly, to
expedite the flow of discovery material, facilitate the
prompt resolution of disputes over confidentiality,
adequately protect material entitled to be kept confidential
and ensure that protection is afforded only to material so
entitled, and for good cause shown, pursuant to the
Court's authority under Federal Rule of Civil Procedure
26(c)(1)(G), and with the consent of the parties, IT
IS HEREBY ORDERED:
“Action” means this pending federal law suit.
“Challenging Party” means a Party or Non-Party
that challenges the designation of information or items under
“CONFIDENTIAL” Information or Items means
information (regardless of how it is generated, stored or
maintained) or tangible things that qualify for protection
under Federal Rule of Civil Procedure 26(c), and as specified
above in the Good Cause Statement. “HIGHLY CONFIDENTIAL
INFORMATION” is information which, if known by the
party to whom it is disclosed, would be inherently harmful to
the Designating Party's business, privacy or other
“Counsel” means Outside Counsel of Record and
House Counsel (as well as their support staff).
“Designating Party” means a Party or Non-Party
that designates information or items that it produces in
disclosures or in responses to discovery as
“CONFIDENTIAL.” 1.6. “Disclosure or
Discovery Material” means all items or information,
regardless of the medium or manner in which it is generated,
stored, or maintained (including, among other things,
testimony, transcripts, and tangible things), that are
produced or generated in disclosures or responses to
discovery in this matter.
“Expert” means a 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 in this Action.
“House Counsel” means attorneys who are employees
of a party to this Action. House Counsel does not include
Outside Counsel of Record or any other outside counsel.
“Non-Party” means any natural person,
partnership, corporation, association, or other legal entity
not named as a Party to this action.
“Outside Counsel of Record” means attorneys who
are not employees of a party to this Action but are retained
to represent or advise a party to this Action and have
appeared in this Action on behalf of that party or are
affiliated with a law firm which has appeared on behalf of
that party, and includes support staff.
“Party” means any party to this Action, including
all of its officers, directors, employees, retained experts,
and Outside Counsel of Record (and their support staffs).
“Producing Party” means a Party or Non-Party that
produces Disclosure or Discovery Material in this Action.
“Professional Vendors” means persons or entities
that provide litigation support services (e.g., photocopying,
videotaping, translating, preparing exhibits or
demonstrations, and organizing, storing, or retrieving data
in any form or medium) and their employees and
“Protected Material” means any Disclosure or
Discovery Material that is designated as
“CONFIDENTIAL” or “HIGHLY
“Receiving Party” means a Party that receives
Disclosure or Discovery Material from a Producing Party.
SCOPE OF THIS PROTECTIVE ORDER
The protections conferred by this Order cover not only
Protected Material (as defined above), but also:
(a) any information copied or extracted from Protected
(b) all copies, excerpts, summaries, or compilations of
Protected Material; and
(c) any testimony, conversations, or presentations by Parties
or their Counsel that might ...