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Cameron v. Great Neck Saw Manufacturers, Inc.

United States District Court, C.D. California, Southern Division

December 26, 2019

ROBERT CAMERON, an individual; and SOUTHWESTERN MFG., a sole proprietorship, Plaintiffs,
v.
GREAT NECK SAW MANUFACTURERS, INC., a New York Corporation; GREAT NECK TOOL & EQUIPMENT, INC., a New York Corporation; THE PEP BOYS MANNY MOE & JACK OF CALIFORNIA, a California Corporation; AUTOSALES, INC., dba SUMMIT RACING, an Ohio Corporation; CARID, a New Jersey Corporation; JEG'S AUTOMOTIVE INC., an Ohio Corporation; AUTOZONE INC., a Tennessee Corporation; and DOES 1 to 10. Defendants.

          Hon. Karen E. Scott Magistrate Judge

          PROTECTIVE ORDER

          HON. DAVID O. CARTER DISTRICT JUDGE.

         P[URSUANT TO STIPULATION OF THE PARTIES, the Court enters the following Order:

         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. Confidential Information will be designated as either CONFIDENTIAL or HIGHLY CONFIDENTIAL - FOR OUTSIDE COUNSEL'S EYES ONLY as set forth below under “General Rules.”

         2. The term "materials" will include, but is not 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 "Outside Counsel" will mean outside counsel of record, and other attorneys, paralegals, secretaries, and other support staff employed in the law firms identified below: FLYER & FLYER, PLC and LEWIS ROCA ROTHGERBER CHRISTIE, LLP and SCHWABE, WILLIAMSON & WYATT, P.C.

         GENERAL RULES

         1. Each party to this litigation 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 the producing party believes to be Confidential Information that should be subject to this Protective Order may designate the same as "CONFIDENTIAL" or "HIGHLY CONFIDENTIAL - FOR OUTSIDE COUNSEL'S EYES ONLY."

         2. Designation as "CONFIDENTIAL": Any party may designate information as "CONFIDENTIAL" only if, in the good faith belief of such party and its counsel, the unrestricted disclosure of such information could be potentially prejudicial to the business or operations of such party.

         3. Designation as "HIGHLY CONFIDENTIAL - FOR OUTSIDE COUNSEL'S EYES ONLY": Any party may designate information as "HIGHLY CONFIDENTIAL - FOR OUTSIDE COUNSEL'S EYES ONLY" only if, in the good faith belief of such party and its counsel, the information is among that considered to be most sensitive by the party, including but not limited to trade secret or other confidential research, development, financial or other commercial information. This information is of such a sensitive proprietary nature that disclosure of the information to persons other than those identified in paragraph 3 in Definitions, above, risks serious competitive injury to the disclosing party.

         4. 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 "HIGHLY CONFIDENTIAL - FOR OUTSIDE COUNSEL'S EYES 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 mark the copies of those materials that contain Confidential Information with the appropriate confidentiality marking.

         5. 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 the deposition or 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 portions of the transcript to be designated "CONFIDENTIAL" or "HIGHLY CONFIDENTIAL - FOR OUTSIDE COUNSEL'S EYES ONLY” and until such designation is made, either on the ...

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