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Fong v. American Medical Systems, Inc.

United States District Court, C.D. California

June 26, 2019

REGINA FONG AND LORENZO FONG, Plaintiffs,
v.
AMERICAN MEDICAL SYSTEMS, INC., AMERICAN MEDICAL SYSTEMS HOLDINGS, INC.; ENDO PHARMACEUTICALS, INC.; ENDO PHARMACEUTICALS HOLDINGS, INC. and DOES 1-40, inclusive, Defendants.

         DISCOVERY MATTER

          AMENDED CONFIDENTIALITY AND PROTECTIVE ORDER

          Honorable Jacqueline Chooljian United States Magistrate Judge

         WHEREAS, Plaintiffs Regina Fong and Lorenzo Fong (“Plaintiff” or “Plaintiffs”), and Defendants Astora Women's Health, LLC (f/k/a American Medical Systems, Inc.), American Medical Systems Holdings, Inc., Endo Pharmaceuticals Inc., and Endo Health Solutions Inc. (f/k/a Endo Pharmaceuticals Holdings Inc.) (collectively, “Defendants”) jointly believe that entry of a protective order pursuant to Federal Rule of Civil Procedure 26(c) should be applied to this matter;

         WHEREAS, a protective order will expedite the flow of discovery material, facilitate the prompt resolution of disputes over confidentiality, and adequately protect confidential material;

         NOW, THEREFORE, having found good cause, it is hereby ORDERED THAT:

         I. Scope of Order

         Disclosure and discovery in this proceeding may involve production of information and/or materials which are claimed to include confidential, proprietary, and private information for which special protection from public disclosure and from any purpose other than prosecuting this litigation may be warranted. Accordingly, the parties hereby stipulate to and petition the court to enter their Stipulated Confidentiality and Protective Order (the “Order”) in this matter. This Order applies equally to CONFIDENTIAL and HIGHLY CONFIDENTIAL material (as defined below) produced/provided and designated as such in this action.

         II. Good Cause Statement

         This action is likely to involve trade secrets, commercial, financial, and/or proprietary information for which special protection from public disclosure and from use for any purpose other than prosecution of this action is warranted. Such confidential and proprietary materials and information consist of, among other things, confidential business or financial information, information regarding confidential business practices, or other confidential research, development, or commercial information (including information implicating privacy rights of third parties), information otherwise generally unavailable to the public, or which may be privileged or otherwise protected from disclosure under state or federal statutes, court rules, case decisions, or common law. Accordingly, to expedite the flow of information, to facilitate the prompt resolution of disputes over confidentiality of discovery materials, to adequately protect information the parties are entitled to keep confidential, to ensure that the parties are permitted reasonable necessary uses of such material in preparation for and in the conduct of trial, to address their handling at the end of the litigation, and serve the ends of justice, a protective order for such information is justified in this matter. It is the intent of the parties that information will not be designated as confidential for tactical reasons and that nothing be so designated without a good faith belief that it has been maintained in a confidential, non-public manner, and there is good cause why it should not be part of the public record of this case.

         III. The Order

         A. Stipulation

         1. By stipulating to the Order, the parties have agreed to be bound by its terms and to request its entry by the Court.

         B. Discovery Phase

         1. For purposes of this Order, the following definitions shall apply: (a) the term “document” and “electronically stored information” shall have the full meanings ascribed to each by the Federal Rules of Civil Procedure and the United States District Court for the Central District of California Local Rules (“Local Rules”), and relevant case law; and (b) the term “producing party” shall be defined ...


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