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Sansone v. Charter Communications, Inc.

United States District Court, S.D. California

November 13, 2017

JENNIFER M. SANSONE, et al., Plaintiff,
v.
CHARTER COMMUNICATIONS, INC., et al., Defendant.

          DENTE LAW, P.C. MESERVY LAW, P.C. Matthew S. Dente London D. Meservy Attorneys for Plaintiffs

          Kabat, Chapman & Ozmer LLP Michael D. Kabat Joseph W. Ozmer J. Scott Carr Nathan D. Chapman Paul G. Sherman Attorneys for Defendant

          ORDER GRANTING JOINT MOTION AND ENTERING STIPULATED PROTECTIVE ORDER [ECF NO. 12]

          HON. JILL L. BURKHARDT UNITED STATES MAGISTRATE JUDGE

         The Court recognizes that at least some of the documents and information ("materials") being sought through discovery in the above-captioned action are, for competitive reasons, normally kept confidential by the parties. The parties have agreed to be bound by the terms of this Protective Order in this action.

         The materials to be exchanged throughout the course of the litigation between the parties may contain trade secret or other confidential research, technical, cost, price, marketing, personnel, or other commercial information, as is contemplated by Federal Rule of Civil Procedure 26(c)(7). The purpose of this Order is to protect the confidentiality of such materials as much as practical during the litigation. Without separate court order, the Protective Order and the parties' stipulation do not change, amend, or circumvent any court rule or local rule. THEREFORE:

         DEFINITIONS

         1. The term "Confidential Information" will mean and include information contained or disclosed in any materials, including documents, portions of documents, answers to interrogatories, responses to requests for admissions, trial testimony, deposition testimony, and transcripts of trial testimony and depositions, including data, summaries, and compilations derived therefrom that is deemed to be Confidential Information by any party to which it belongs.

         2. The term "materials" will include, but is not be limited to: documents; correspondence; memoranda; bulletins; blueprints; specifications; customer lists or other material that identify customers or potential customers; personnel lists or rosters; price lists or schedules or other matter identifying pricing; minutes; telegrams; letters; statements; cancelled checks; contracts; invoices; drafts; books of account; worksheets; notes of conversations; desk diaries; appointment books; expense accounts; recordings; photographs; motion pictures; compilations from which information can be obtained and translated into reasonably usable form through detection devices; sketches; drawings; notes (including laboratory notebooks and records); reports; instructions; disclosures; other writings; models and prototypes and other physical objects.

         3. The term "counsel" will mean outside counsel of record, and other attorneys, paralegals, secretaries, and other support staff employed in the law firms identified below: Kabat Chapman & Ozmer LLP, Meservy Law, P.C., and Dente Law, P.C. in-house attorneys for Charter Communications, Inc.

         GENERAL RULES

         4. Each party to this litigation that produces or discloses any materials, answers to interrogatories, responses to requests for admission, trial testimony, deposition testimony, and transcripts of trial testimony and depositions, or information that the producing party believes should be subject to this Protective Order may designate the same as "CONFIDENTIAL" or "CONFIDENTIAL - FOR COUNSEL ONLY."

a. Designation as "CONFIDENTIAL": Any party may designate information as "CONFIDENTIAL" only if, in the good faith belief of such party and its counsel that the information is personally sensitive information (such as home addresses, dates of birth, social security numbers, medical records, or similar information) or could be potentially prejudicial to the business or operations of such party such that the unrestricted use and disclosure of such information should not be permitted.
b. Designation as "CONFIDENTIAL - FOR COUNSEL ONLY": Any party may designate information as "CONFIDENTIAL - FOR COUNSEL ONLY" only if, in the good faith belief of such party and its counsel, the information is among that considered to be most sensitive by the party, including but not limited to trade secret or other confidential research, development, financial or other commercial information.

         5. In the event the producing party elects to produce materials for inspection, no marking need be made by the producing party in advance of the initial inspection. For purposes of the initial inspection, all materials produced will be considered as "CONFIDENTIAL - FOR COUNSEL ONLY, " and must be treated as such pursuant to the terms of this Order. Thereafter, upon selection of specified materials for copying by the inspecting party, the producing party must, within a reasonable time prior to producing those materials to the ...


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