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Kurtz v. Samsung Electronics America, Inc.

United States District Court, C.D. California

May 4, 2018

JON KURTZ, Plaintiff,
v.
SAMSUNG ELECTRONICS AMERICA, INC., and SAMSUNG ELECTRONICS CO., LTD., Defendants. SAMSUNG ELECTRONICS AMERICA, INC., and SAMSUNG ELECTRONICS CO., LTD., Counterclaimants,
v.
JON KURTZ, Counterdefendant.

          MARK D. FOWLER, AARON WAINSCOAT, ERIK R. FUEHRER DLA PIPER LLP (US) PATRICK S. PARK DLA PIPER LLP (US) ATTORNEYS FOR DEFENDANTS AND COUNTERCLAIMANTS SAMSUNG ELECTRONICS CO., LTD. AND SAMSUNG ELECTRONICS AMERICA, INC.

          TUCKER ELLIS LLP BRIAN K. BROOKEY STEVEN E. LAURIDSEN ATTORNEYS FOR PLAINTIFF, JON KURTZ

          Hon. S. James Otero Judge

          PROTECTIVE ORDER

          Hon. Jean P. Rosenbluth United States District Court Judge

         Pursuant to the stipulation for entry of a protective order governing confidentiality of the parties, and for good cause shown, IT IS ORDERED that the parties' stipulation is approved and shall be the Order of the Court as follows:

         1. This Order governs the treatment of documents, [1] transcripts of and exhibits to depositions, interrogatory answers, responses to requests for admissions, and other written, recorded, or graphic material, including all copies, excerpts, abstracts, or summaries thereof (collectively, “Discovery Material”), produced, filed with the Court, served, or obtained by any party or non-party in this action (collectively, “Person(s)”). By entering into this Stipulation, the parties do not waive in any manner, their rights and remedies under Rule 26(b) of the Federal Rules of Civil Procedure.

         2. Any Person shall have the right, before disclosure to other parties, to designate as “CONFIDENTIAL” or “CONFIDENTIAL - ATTORNEYS' EYES ONLY” any Discovery Material it produces or provides that the party and an attorney or legal assistant on behalf of the party in good faith believe constitutes, reflects or discloses its trade secrets or other confidential research, development, or commercial information within the scope of Fed.R.Civ.P. 26(c)(1)(G).

         3. Discovery Material designated as “CONFIDENTIAL” shall be limited to Discovery Material that the designating Person believes in good faith must be held confidential to protect business or commercial interests.

         4. Discovery Material designated as “CONFIDENTIAL - ATTORNEYS' EYES ONLY” shall be limited to Discovery Material that the designating Person believes in good faith is so commercially sensitive or confidential that the disclosure to employees, principals, and/or officers/directors of another party, even under the restricted terms and conditions applicable to material designated “CONFIDENTIAL, ” would not provide adequate protection to the interests of the producing Person.

         5. All Discovery Material designated as either “CONFIDENTIAL” OR “CONFIDENTIAL - ATTORNEYS' EYES ONLY, ” and all information derived therefrom, shall be referred to in this Stipulation as “Designated Material” and shall be handled in strict accordance with the terms of this Stipulation. Specifically, absent an order by this Court, such Designated Material shall be used by the parties to this action solely in connection with this action or any appeal therefrom, and not for any other purpose, or any business, patent prosecution, competitive, or governmental purpose or function, and such Designated Material shall not be disclosed to anyone except as provided herein. Designated Material may not be disclosed to anyone except as provided herein. Designated Material may be disclosed only under the circumstances and to the persons specifically provided for in this Stipulation or any subsequent Court order, or with the explicit written consent of the designating Person with respect to specifically identified Designated Material.

         6. Discovery Material designated as “CONFIDENTIAL” or information derived therefrom may be disclosed, shown, or made available, or communicated in any way to the following persons:

a. Attorneys of record for the parties to this litigation who have appeared in this litigation or are affiliated with a law firm that has appeared on behalf of a party, including persons working solely in secretarial, clerical, and paralegal capacities, and who are providing assistance to counsel in this action;
b. in-house attorneys for the parties, including persons working solely in secretarial, clerical, and paralegal capacities, and who are providing assistance to in-house counsel in this action;
c. qualified persons taking testimony involving Designated Material, and necessary stenographic, videographic, and clerical personnel thereof;
d. consultants or experts and their staff who are employed for the purposes of this litigation, provided that the provisions of Paragraph 11 and 12 of this Stipulation are complied with prior to any disclosure of any Designated Material to such an expert or consultant;
e. the Court and the Court's staff pursuant to Paragraph 14 of this Stipulation or as ordered by the Court;
f. the parties and employees of the parties, but only to the extent necessary to participate in, assist in and monitor the progress of this action and for no other purpose;
g. third-parties specifically retained to assist outside counsel in copying, imaging, and/or coding of documents but for that purpose only, provided that all such confidential documents are kept and maintained in a separate and secure place and that the third party retained to copy, image, or code confidential documents is not currently performing any services, either as an employee, consultant, or otherwise for any competitor of either party to this action or for one having any interest adverse to either party to this action;
h. witnesses deposed in this action or who are called as witnesses at any discovery-related hearing in this action, but for only as set forth in Paragraph ...

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