United States District Court, N.D. California
HEIDE M. VELARDE, Plaintiff,
COUNTY OF ALAMEDA, et al., Defendants.
PROTECTIVE ORDER FOR STANDARD LITIGATION
PURPOSES AND LIMITATIONS
and discovery activity in this action are likely to involve
production of confidential, proprietary, or private
information for which special protection from public
disclosure and from use for any purpose other than
prosecuting this litigation may be warranted. Accordingly,
the parties hereby stipulate to and petition the court to
enter the following Stipulated Protective Order. The parties
acknowledge that this Order does not confer blanket
protections on all disclosures or responses to discovery and
that the protection it affords from public disclosure and use
extends only to the limited information or items that are
entitled to confidential treatment under the applicable legal
principles. The parties further acknowledge, as set forth in
Section 12.3, below, that this Stipulated Protective Order
does not entitle them to file confidential information under
seal; Civil Local Rule 79-5 sets forth the procedures that
must be followed and the standards that will be applied when
a party seeks permission from the court to file material
Challenging Party: a Party or Non-Party that
challenges the designation of information or items under this
“CONFIDENTIAL” Information or Items:
(regardless of how it is generated, stored or maintained) or
tangible things that qualify for protection under Federal
Rule of Civil Procedure 26(c).
Counsel (without qualifier):
Counsel of Record and House Counsel (as well as their support
or Non-Party that designates information or items that it
produces in disclosures or in responses to discovery as
Disclosure or Discovery Material:
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.
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 or as a
consultant in this action.
who are employees of a party to this action. House Counsel
does not include Outside Counsel of Record or any other
natural person, partnership, corporation, association, or
other legal entity not named as a Party to this action.
Outside Counsel of Record:
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
party to this action, including all of its officers,
directors, employees, consultants, retained experts, and
Outside Counsel of Record (and their support staffs).
or Non-Party that produces Disclosure or Discovery Material
in this action.
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
Disclosure or Discovery Material that is designated as
“CONFIDENTIAL.” 2.14 Receiving Party: a
Party that receives Disclosure ...