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Dizon v. The Hertz Corp.

United States District Court, S.D. California

December 10, 2019

WILLIAM DIZON, Plaintiff,
v.
THE HERTZ CORPORATION, Defendant.

          ORDER GRANTING JOINT MOTION FOR PROTECTIVE ORDER; AND ENTERING PROTECTIVE ORDER [ECF NO. 14]

          Hon. Jill L. Burkhardt United States Magistrate Judge

         Before the Court is the parties' Joint Motion for Protective Order. (ECF No. 14.) For good cause shown, the parties' Joint Motion is GRANTED, and the following Protective Order is entered:

         In order to facilitate the exchange of information and documents (“materials”) which may be subject to confidentiality limitations on disclosure due to federal laws, state laws, and privacy rights, the parties have agreed to enter into this Stipulation and Protective Order (“Protective Order” or “Order”). The materials to be exchanged throughout the course of the litigation between the parties may contain trade secret or other confidential research, technical, cost, price, marketing or other commercial information, as is contemplated by Federal Rule of Civil Procedure 26(c)(1)(G). The purpose of this Order is to protect the confidentiality of such materials as much as practical during the litigation. THEREFORE:

         DEFINITIONS

         1. 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 testimony, 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.

         2. The term “materials” will include, but is not be limited to: documents; correspondence; memoranda; bulletins; blueprints; specifications; customer lists or other material that identify customers or potential customers; price lists or schedules or other matter identifying pricing; minutes; telegrams; letters; statements; cancelled checks; contracts; invoices; drafts; books of account; worksheets; notes of conversations; desk diaries; appointment books; expense accounts; recordings; photographs; motion pictures; compilations from which information can be obtained and translated into reasonably usable form through detection devices; sketches; drawings; notes (including laboratory notebooks and records); reports; instructions; disclosures; other writings; models and prototypes and other physical objects.

         3. The term “counsel” will mean outside counsel of record, and other attorneys, paralegals, secretaries, and other support staff employed in the law firms identified below: Winston & Strawn, LLP, Counsel for Defendant The Hertz Corporation; and Berger, Williams & Reynolds, LLP, Counsel for Plaintiff William Dizon. Counsel also includes Leslie Simoneau, in-house attorney for Defendant The Hertz Corporation.

         GENERAL RULES

         4. Each party subject to this Protective Order that produces or discloses any materials, answers to interrogatories, responses to requests for admission, trial testimony, deposition testimony, and transcripts of trial testimony and depositions, or information that such party believes should be subject to this Protective Order may designate the same as “CONFIDENTIAL” or “CONFIDENTIAL - FOR COUNSEL ONLY.”

a) Designation as “CONFIDENTIAL”: Any party subject to this Protective Order may designate materials as “CONFIDENTIAL” only if, in the articulable, good faith belief of such party, the materials qualify for protection under Federal Rule of Civil Procedure 26(c).
b) Designation as “CONFIDENTIAL - FOR COUNSEL ONLY”: Any party subject to this Protective Order may designate information as “CONFIDENTIAL - FOR COUNSEL ONLY” only if, in the articulable, good faith belief of such party, the materials qualify for protection under Federal Rule of Civil Procedure 26(c) and are among those materials considered to be most sensitive by such party, including but not limited to trade secret or other confidential research, development, financial or other commercial information.

         5. In the event the producing party elects to produce materials for inspection, no marking need be made by the producing party in advance of the initial inspection. For purposes of the initial inspection, all materials produced will be considered as “CONFIDENTIAL - FOR COUNSEL ONLY, ” and must be treated as such pursuant to the terms of this Order. Thereafter, upon selection of specified materials for copying by the inspecting party, the producing party must, within a reasonable time prior to producing those materials to the inspecting party, mark the copies of those materials that contain confidential information with the appropriate confidentiality marking.

         6. Whenever a deposition taken on behalf of any party involves a disclosure of confidential information of any party:

a) The deposition or portions of the deposition must be designated as containing confidential information subject to the provisions of this Order; such designation must be made on the record whenever possible, but a party may designate portions of depositions as containing confidential information after transcription of the proceedings; a party will have until fourteen (14) days after receipt of the deposition transcript to inform the other party or parties to the action of the ...

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