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In re Complaint of Francis

United States District Court, S.D. California

November 22, 2017

In the matter of the Complaint of MARK S. FRANCIS and WENDY P. FRANCIS, as owners of the vessel “Fortuna, ” For exoneration from, or limitation of, liability.

          COX, WOOTTON, LERNER, GRIFFIN & HANSEN LLP Alena A. Eckhardt, Esq. Attorneys for Plaintiffs-in-Limitation MARK S. FRANCIS AND WENDY P. FRANCIS

          LAW OFFICES OF ELLIOTT KANTER, Elliott N. Kanter Attorney for Claimant JASON ANDERSON

          LAW OFFICES OF STEVEN A. ELIA, Steven A. Elia Holly Attiq Maura Griffin Attorneys for Claimants DALE and ANA ANDERSON

          CHARMASSON BUCHACA & LEACH, Rob G. Leach Randy S. Perlman Attorneys for Claimant TATIANA SANCHEEVA

          PETTIT KOHN INGRASSIA LUTZ & DOLIN PC Jennifer N. Lutz, Esq. Attorneys for Third Party AQUANEERING, INC.

          STIPULATED PROTECTIVE ORDER [1]

          Jan M. Adler, United States Magistrate Judge

         I. 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. The purpose of the Protective Order is to allow the parties to have reasonable access to information from the other party with the means of limiting access to, and disclosure of, Confidential Information that is protected in this lawsuit without frequent resort to determinations of discoverability by the Court.

         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.

         II. DEFINITIONS

         1. When used in this Order, the word “documents” shall have the full meaning ascribed to the term “writings” as set forth in Federal Rule of Evidence 1001(1) and shall include, without limitation, all originals written, recorded, or graphic matters and all copies thereof.

         2. 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 and 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.

         3. The term “Discovery Materials” will mean any document or portion(s) thereof, testimony, or other information produced in this action through disclosure or discovery procedures by any party.

         4. The term “Confidential Discovery Materials” shall mean Discovery Materials designated as “CONFIDENTIAL.”

         III. GENERAL RULES

         5. Each party to this litigation that produces or discloses any materials, answers to interrogatories, responses to request for admissions, trial testimony, deposition testimony and transcripts of trial testimony and depositions, or information that the producing party believes should be subject to the Protective Order may designate the same as “CONFIDENTIAL.” 6. All Confidential Discovery Materials (as defined in section II (4) above) produced or disclosed in this action shall be used solely for the prosecution and/or defense of any action between the parties. Any person who has been provided Confidential Discovery Materials in this action shall maintain them in a reasonably secure manner so as to avoid disclosure of their contents.

         7. Discovery materials may be designated “CONFIDENTIAL” by the producing party who believes in good faith that the unrestricted disclosure of such information could be potentially prejudicial to the protected privacy rights, business, or operations of such party and/or any party's employees or clients.

         8. Discovery Materials designated “CONFIDENTIAL” shall be referred t o herein as “Confidential Discovery Materials.” Confidential Discovery Materials include materials and documents that constitute or reflect parties' confidential business and financial information, the disclosure of which may be prejudicial to parties' protected privacy rights, business or operations, and/or information that may be protected by any third party's right to privacy under the United States or California Constitutions. Materials provided by one party to the other informally in the course of this action may be brought within the terms of the Protective Order by written notification to counsel receiving such Materials at the time of any such exchange.

         9. The “CONFIDENTIAL” designation provided for in this Order may be made at or prior to the time of production of documents by stamping the word “Confidential” on each page of the matter disclosed or conspicuously on the front of other media containing information (e.g., CD or DVD), or, in the case of depositions, as provided in section III(10) below. Inadvertent failure to designate materials as “Confidential” at the time of production may be remedied thereafter by written notice of supplemental production of the Discovery Materials with the “Confidential” designation. Upon the service of such notice and supplemental production, the Discovery Materials shall be subject to the Protective Order as if ...


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