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Very Good Touring, Inc. v. Cathedral Syndicate 2010 of Lloyd's of London

United States District Court, C.D. California

November 17, 2017

VERY GOOD TOURING, INC., Plaintiff,
v.
CATHEDRAL SYNDICATE 2010 OF LLOYD'S OF LONDON, a foreign company-LIBERTY SYNDICATE 4472 OF LLOYD'S OF LONDON, a foreign company; XL CATLIN SYNDICATE 2003 OF LLOYD'S OF LONDON, a foreign company MARKEL SYNDICATE 3000 OF LLOYD'S OF LONDON a foreign company; ALLIANZ SYNDICATE OF LLOYD'S OF LONDON, a foreign company, Defendants. AND RELATED COUNTERCLAIM

          KING, HOLMES, PATERNO & SORIANO. LLP Howard E. King, Esq., State Bar No. 77012 Seth Miller, Esq., State Bar No. 175130 Attorneys for Plaintiff/Counterdefendant VERY GOOD TOURING, INC.

          P.K.SCHRIEFFER LLP Paul K. Schrieffer, Esq., State Bar No. 151358 Wayne H. Hammack, Esq., State Bar No. 202709 Attorneys for Defendants and Counterclaimants, CATHEDRAL SYNDICATE: 2010, a.k.a. CATHEDRAL SYNDICATE MMX, ATLLOYD'S OF LONDON, a foreign company; LIBERTY SYNDICATE 4472 AT LLOYD'S OF LONDON, A FOREIGN COMPANY; XL CATLIN SYNDICATE 2003 OF LLOYD'S OF LONDON, A FOREIGN COMPANY; MARKEL SYNDICATE 3000 OF LLOYD'S OF LONDON, a foreign company; ALLIANZ GLOBAL CORPORATE & SPECIALTY SE. a foreign company (erroneously sued as ALLIANZ SYNDICATE OF LLOYD'S OF LONDON, a foreign company)

          DISCOVERY MATTER: [PROPOSED] PROTECTIVE ORDERS

          Hon. Charles F. Eick, United States Magistrate Judge

         IT IS HEREBY ORDERED that a Stipulated Protective Order will govern the production and exchange of confidential information in the above-captioned case on the following terms:

         TERMS OF THE STIPULATED PROTECTIVE ORDER

         1. PURPOSES AND LIMITATIONS

         Disclosure 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. Certain materials which may have been, or hereafter may be, presented produced for inspection or copying, or provided or referenced in propounded in discovery or set out in discovery responses, are also governed by written non-disclosure agreements involving parties hereto ("NDA")- 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.

         2. DEFINITIONS

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

         2.2 "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 maybe disclosed only to the persons described in Paragraph 7.2 below:

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

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

         2.5 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.

         2.6 For the purposes of this Order, the words "document" and "documents" are used in the broadest possible sense and refer, without limitation, to documents as they are defined in Fed. Rule of Civ. Pro. 34(a)(1)(A) and 34(b)(2)(B).

         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 House Counsel: attorneys who are employees of a party to this action. House Counsel does not include Outside Counsel of Record any other outside counsel. Such House Counsel shall fill out and execute the form of Acknowledgement and Agreement to Be Bound, in the form attached hereto as Exhibit A before reviewing or inspecting any CONFIDENTIAL Information or Items.

         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 as counsel of record on behalf of that party or are directly affiliated with a law firm which has appeared of record on behalf of that party.

         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. However, the protections conferred by this Stipulation and Order do not cover the following information: (a) any information that is in the public domain at the time of disclosure to a Receiving Party or becomes part of the public domain after its disclosure to a Receiving Party as a result of publication not involving a violation of this Order, including becoming part of the public record through trial or otherwise; and (b) any information known to the Receiving Party prior to the disclosure or obtained by the Receiving Party after the disclosure from a source who obtained the information lawfully and under no obligation of confidentiality to the Designating Party. Any use of Protected Material at trial shall be governed by a separate agreement or order.

         4. DURATION

         Even after final disposition of this litigation, the confidentiality obligations imposed by this Order shall remain in effect until a Designating Party agrees otherwise in writing or a Court order otherwise directs. Final disposition shall be deemed to be the later of (1) dismissal of all claims and defenses in this action, with or without prejudice; and (2) final judgment herein after the completion and exhaustion of all appeals, rehearings, remands, trials, or reviews of this action, including the time limits for filing any motions or applications for extension of time pursuant to applicable law. Nothing in this Order shall serve to relieve any Party, or their ...


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