Searching over 5,500,000 cases.


searching
Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.

Mcelroy v. Eriksen

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

June 7, 2017

THOMAS DERRICK MCELROY, et al., Plaintiffs,
v.
MIKKEL S. ERIKSEN, etc., et al., Defendants.

          Peter J. Anderson, Esq., Cal. Bar No. 88891 LAW OFFICES OF PETER J. ANDERSON A Professional Corporation Attorney for Defendant WB MUSIC CORP.

          [PROPOSED] PROTECTIVE ORDER

          HON. ANDREW J. WISTRICH, UNITED STATES MAGISTRATE JUDGE

         PROTECTIVE ORDER

         The 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:

         1. DEFINITIONS

         1.1. “Action” means this pending federal law suit.

         1.2. “Challenging Party” means a Party or Non-Party that challenges the designation of information or items under this Order.

         1.3. “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 protected interests.

         1.4. “Counsel” means Outside Counsel of Record and House Counsel (as well as their support staff).

         1.5. “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.

         1.7. “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.

         1.8. “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.

         1.9. “Non-Party” means any natural person, partnership, corporation, association, or other legal entity not named as a Party to this action.

         1.10. “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.

         1.11. “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).

         1.12. “Producing Party” means a Party or Non-Party that produces Disclosure or Discovery Material in this Action.

         1.13. “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 subcontractors.

         1.14. “Protected Material” means any Disclosure or Discovery Material that is designated as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL.”

         1.15. “Receiving Party” means a Party that receives Disclosure or Discovery Material from a Producing Party.

         2. SCOPE OF THIS PROTECTIVE ORDER

         2.1. The protections conferred by this Order cover not only Protected Material (as defined above), but also:

(a) any information copied or extracted from Protected Material;
(b) all copies, excerpts, summaries, or compilations of Protected Material; and
(c) any testimony, conversations, or presentations by Parties or their Counsel that might ...

Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.