United States District Court, E.D. California
Group Inc, Nathan A. Searles Attorney for Defendant Portfolio
Recovery Associates, LLC
WEGER, Amy L.B. Ginsburg Attorney for Plaintiff LESLIE WEGER.
ORDER GRANTING JOINT MOTION FOR PROTECTIVE
F. Brennan United States Magistrate Judge.
to the parties' Joint Motion for Protective Order, and
good cause appearing, it is hereby ordered that:
Protective Order agreed to by the Parties, and attached
hereto, be ordered effective by the Court.
to Rule 26(c) of the Federal Rules of Civil Procedure,
Plaintiff, LESLIE WEGER and Defendant, PORTFOLIO RECOVERY
ASSOCIATES, LLC, by undersigned counsel, hereby jointly agree
and stipulate to the following provisions with respect to all
Parties' confidential documents and information in the
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,
plaintiff LESLIE WEGER and defendant PORTFOLIO RECOVERY
ASSOCIATES, LLC (“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
141 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.
Challenging Party: a Party or Non-Party that challenges the
designation of information or items under this Order.
“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).
Counsel (without qualifier): Outside Counsel of Record and
House Counsel (as well as their support staff).
Designating Party: a Party or Non-Party that designates
information or items that it produces in disclosures or in
responses to discovery as “CONFIDENTIAL.”
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.
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.
House Counsel: attorneys who are employees of a party to this
action. House Counsel does not include Outside Counsel of
Record or any other outside counsel.
Non-Party: any natural person, partnership, corporation,
association, or other legal entity not named as a Party to
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.
Party: any party to this action, including all of its
officers, directors, employees, consultants, retained
experts, and Outside Counsel of Record (and their support
Producing Party: a Party or Non-Party that produces
Disclosure or Discovery Material in this action.
Professional Vendors: persons or entities that provide
litigation support services (e.g., photocopying, videotaping,
translating, preparing exhibits or demonstrations, and
organizing, storing, or retrieving ...