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Ortolani v. Freedom Mortgage Corp.

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

November 15, 2017

GABRIELA ORTOLANI, individually and on behalf of all other similarly situated, Plaintiff,
v.
FREEDOM MORTGAGE CORPORATION, an unknown entity, and DOES 1 through 50, inclusive, Defendants.

          BLANK ROME LLP Michael L. Ludwig (SBN 173850) Caroline P. Donelan (SBN 268762) Caitlin I. Sanders (SBN 294143) Attorneys for Defendant FREEDOM MORTGAGE CORPORATION

          YOON LAW, APC Kenneth H. Yoon (SBN 198443) Stephanie E. Yasuda (SBN 265480) Attorneys for Plaintiff Gabriela Ortolani

          JOINT MOTION FOR ENTRY OF PROTECTIVE ORDER

          MAGISTRATE JUDGE KENLY KIYA KATO

         1. A. PURPOSES AND LIMITATIONS

         Discovery in this action is 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 tofile 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 under seal.

         B. GOOD CAUSE STATEMENT

         This action is likely to involve trade secrets, confidential personnel documents and compensation-structure information for which special protection from public disclosure and from use for any purposes other than the prosecution of this action is warranted. Such confidential and proprietary materials and information consist of, among other things, confidential business or financial information, information regarding confidential business practices or other confidential personnel information that implicates the privacy rights of third parties, information otherwise generally unavailable to the public, or which may be privileged or otherwise protected from disclosure under state or federal statutes, court rules, case decisions, or common law. Accordingly, to expedite the flow of information, to facilitate the prompt resolution of disputes over confidentiality of discovery materials, to adequately protect information the parties are entitled to keep confidential, to ensure that the parties are permitted reasonably necessary uses of such material in preparation for an in the conduct of trial, to address their handling at the end of the litigation, and serve the ends of justice, a protective order for such information is justified in this matter. It is the intent of the parties that information will not be designated as confidential for tactical reasons and that nothing be so designated without a good-faith belief that it has been maintained in a confidential, non-public manner, and there is good cause why it should not be part of the public record of this case.

         2. DEFINITIONS

         2.1. Action: Gabriela Ortolani v. Freedom Mortgage Corporation, United States District Court Case No. 5:17-cv-01462-JGB-KK

         2.2. Challenging Party: a Party or Non-Party that challenges the designation of information or items under this Order.

         2.3. “CONFIDENTIAL” Information or Items: 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.

         2.4. Counsel (without qualifier): Outside Counsel of Record and In-House Counsel (as well as their support staff).

         2.5. Designating Party: a Party or Non-Party that designates information or items that it produces in disclosures or in responses to discovery as “CONFIDENTIAL.”

         2.6. Disclosure or Discovery Material: 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.

         2.7. Expert: 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 or as a consultant in this Action.

         2.8. In-House Counsel: attorneys who are employees of a party to this action. In-House Counsel does not include Outside Counsel of Record or any other outside counsel.

         2.9. Non-Party: any natural person, partnership, corporation, association, or other legal entity not named as a Party to this action.

         2.10. Outside Counsel of Record: 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.

         2.11. Party: any party to this action, including all of its officers, directors, employees, consultants, retained experts, and Outside Counsel of Record (and their support staffs).

         2.12. Producing Party: a Party or Non-Party that produces Disclosure or Discovery Material in this Action.

         2.13. Professional Vendors: 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.

         2.14. Protected Material: any Disclosure or Discovery Material that is designated as “CONFIDENTIAL.”

         2.15. Receiving Party: a Party that receives Disclosure or Discovery Material from a Producing Party.

         3. SCOPE

         The protections conferred by this Stipulation and Order cover not only Protected Material (as defined above), but also (1) any information copied or extracted from Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected Material; and (3) any testimony, conversations, or presentations by Parties or their Counsel that might reveal Protected Material.

         Any use of Protected Material at trial shall be governed by the orders of the trial judge. This Order does not govern ...


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