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Termendzhyan v. Costco Wholesale, Inc.

United States District Court, C.D. California

June 21, 2019

MARINE TERMENDZHYAN, Plaintiff
v.
COSTCO WHOLESALE, INC., a corporation; and DOES 1- 50, inclusive Defendants.

          Michael Miretsky, Esq., David H. Lieberthal, Esq., LEIBL, MIRETSKY & MOSELY, LLP Attorneys for Defendant, COSTCO WHOLESALE CORPORATION

          [PROPOSED] PROTECTIVE ORDER

         TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:

         THE COURT, having reviewed and approved the Stipulation of Parties re: Protective Materials, entered into by and between, Plaintiff MARINE TERMENDZHYAN and Defendant COSTCO WHOLESALE CORPORATION (collectively, the "parties"), hereby enters the following protective order:

         FOR GOOD CAUSE SHOWN, IT IS SO ORDERED THAT:

         1. During the discovery process in this case, it is expected that the parties may disclose documents that a party contends are confidential and/or commercially sensitive in such that a protective order is necessary to adequately protect the confidentiality of the information or materials.

         2. A protective order will enable the parties to expedite the discovery process, to protect information claimed by any of the parties to be confidential, proprietary, and trade secret from public disclosure, and resolve disputes over confidentiality promptly.

         3. This Stipulation which allows producing parties to designate applicable documents or groups of documents as containing confidential information subject to objection by the requesting parties, and maintaining with the producing party the burden of proving that good cause exists for the confidential designation, is the least restrictive alternative to protect against any harm that may result from the dissemination of these documents absent this Stipulation. This Stipulation attempts to strike the proper balance between the legitimate interests of the parties in the protection of their confidential materials, the discovery and use in this litigation of the materials requested and produced, and the legitimate interests of non-parties in the dissemination and use of discovery material.

         4. This Stipulation shall govern the use and dissemination of the following "documents."

         5. The term "document" or "documents" means (1) all written, recorded or graphic matter whatever, including materials stored in electronic media, and information produced on computer disks or tapes, including all "Writings" as that term is defined by California Evidence Code § 250, produced in this action by any party or by any non-party, whether pursuant to the Code of Civil Procedure, subpoena, or by agreement; and (2) any copies, reproductions, or summaries of the foregoing, including microfilm copies. Interrogatory answers, responses to requests for admission, transcripts of depositions or other statement under oath and exhibits thereto, pleadings, motions, affidavits, and briefs that quote, summarize, or contain materials entitled to protection may be accorded status as stamped confidential documents, but, to the extent feasible, shall be prepared in such a manner that the confidential information is bound separately from that not entitled to protection.

         Confidential Information

         6. The terms "Confidential Information" and "Confidential Documents", as used in this Stipulation, is defined to include information or materials that constitute or contain the following information: Confidential business, proprietary, and/or trade secret information, which, even in limited use by another party to this litigation or any third party, would risk the loss of a significant competitive advantage.

         7. Any party to this action or other person or entity, including any third party, who produces or supplies information, documents or other materials used in this action (hereinafter the "Designating Party" or the "Producing Party") may designate as "Confidential Documents" any information, document, or material that it reasonably and in good faith believes constitutes or contains Confidential Information. Designating Parties shall designate "Confidential Documents" as follows:

a. In the case of documents other than transcripts of witness testimony and documents produced in non-paper media, the designation "Confidential Documents" shall be made by affixing to all pages of the document or material containing such information, and upon each page so designated, a legend that in substance states: "CONFIDENTIAL, PROTECTED BY COURT ORDER, CASE NO. 2:18-cv-01646 AB(Ex) (UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA)".
b. In the case of depositions or other testimony (including exhibits), a Designating Party may designate the transcript a Confidential Document by indicating that fact on the record during the deposition or examination under oath, or by thereafter notifying the court reporter and the other parties in writing of the portions of such deposition or other testimony to be so designated within twenty (20) days of receipt of the initial electronic transcript (not including real time transcription or rough transcripts) from the court reporter. If a Designating Party has advised the court reporter that Confidential Information has been disclosed during a deposition or examination under oath, the court reporter shall include on the cover page of the transcript the following indication: "DEPOSITION [or EXAMINATION] CONTAINS CONFIDENTIAL INFORMATION OF [NAME OF DESIGNATING PARTY] -SUBJECT TO PROTECTIVE ORDER IN CASE NO. 2:18-cv-01646 AB(Ex) (UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA)". Within twenty (20) days of receipt of the initial electronic transcript from the court reporter, the Designating Party shall advise the court reporter and opposing counsel of the specific pages and lines in which Confidential Information appears. The court reporter shall supplement the transcript to mark the specific pages ...

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