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Stipulation And Protective Order-Confidential And Highly Confidential Designations - California

Stipulation And Protective Order-Confidential And Highly Confidential Designations Form. This is a California form and can be used in Model Protective Orders Los Angeles Local County .
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1 Where the Parties wish to have a confidentiality stipulation and protective order the parties in all civil cases, other than products liability cases, are encouraged to use this Stipulated Confidentiality 2 Order Form as an initial working draft to save time. 3 Where this Stipulated Confidentiality Order Form is used, then any proposed stipulated confidentiality order submitted to the Court MUST be accompanied by a "redlined' or "compare" 4 version of this Form, so that the Court may readily see ALL MODIFICATIONS that were made to this Form. This procedure is intended to save you and the Court time, and promote faster processing 5 of these proposed orders. 6 7 8 9 10 11 12 13 This model form confidentiality stipulation and protective order (the "Stipulated Confidentiality Order Form") does not address, and may not be used in, products liability cases. SUPERIOR COURT OF CALIFORNIA 14 COUNTY OF LOS ANGELES 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Plaintiffs, vs. Defendants. Case No. LOS ANGELES MODEL STIPULATION AND PROTECTIVE ORDER ­ CONFIDENTIAL AND HIGHLY CONFIDENTIAL DESIGNATIONS IT IS HEREBY STIPULATED by and between the Parties to Plaintiffs v. Defendants, (list names of Plaintiffs and Defendants), by and through their respective counsel of record, that in order to facilitate the exchange of information and documents which may be subject to confidentiality limitations on disclosure due to federal laws, state laws, and privacy rights, the Parties stipulate as follows: 1 American LegalNet, Inc. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 1. In this Stipulation and Protective Order, the words set forth below shall have the following meanings: a. b. "Proceeding" means the above-entitled proceeding (specify case number). "Court" means the Hon. (list name of judge), or any other judge to which this Proceeding may be assigned, including Court staff participating in such proceedings. c. [This provision is only to be used when a legitimate basis, tailored to the "Highly Confidential" means any information which belongs to a case, has been explained.] Designating Party who believes in good faith that the Disclosure of such information to another Party or non-Party would create a substantial risk of serious financial or other injury that cannot be avoided by less restrictive means. d. "Confidential Materials" means any Documents, Testimony or Information as defined below designated as "Highly Confidential" pursuant to the provisions of this Stipulation and Protective Order. e. Confidential." f. "Disclose" or "Disclosed" or "Disclosure" means to reveal, divulge, give, or "Designating Party" means the Party that designates Materials as "Highly make available Materials, or any part thereof, or any information contained therein. g. "Documents" means (i) any "Writing," "Original," and "Duplicate" as those terms are defined by California Evidence Code Sections 250, 255, and 260, which have been produced in discovery in this Proceeding by any person, and (ii) any copies, reproductions, or summaries of all or any part of the foregoing. h. i. "Information" means the content of Documents or Testimony. "Testimony" means all depositions, declarations or other testimony taken or used in this Proceeding. 2. The Designating Party shall have the right to designate as "Highly Confidential" only the non-public Documents, Testimony or Information that the Designating Party in good faith believes would create a substantial risk of serious financial or other injury, if Disclosed to another Party or non-Party, and that such risk cannot be avoided by less restrictive means. 2 American LegalNet, Inc. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3. The entry of this Stipulation and Protective Order does not alter, waive, modify, or abridge any right, privilege or protection otherwise available to any Party with respect to the discovery of matters, including but not limited to any Party's right to assert the attorney-client privilege, the attorney work product doctrine, or other privileges, or any Party's right to contest any such assertion. 4. Any Documents, Testimony or Information to be designated as "Highly Confidential" must be clearly so designated before the Document, Testimony or Information is Disclosed or produced. The parties may agree that the case name and number are to be part of the "Highly Confidential" designation. The "Highly Confidential" designation should not obscure or interfere with the legibility of the designated Information. a. For Documents (apart from transcripts of depositions or other pretrial or trial proceedings), the Designating Party must affix the legend "Highly Confidential" on each page of any Document containing such designated Confidential Material. b. For Testimony given in depositions the Designating Party may either: i. identify on the record, before the close of the deposition, all "Highly Confidential" Testimony, by specifying all portions of the Testimony that qualify as "Highly Confidential;" or ii. designate the entirety of the Testimony at the deposition as "Highly Confidential" (before the deposition is concluded) with the right to identify more specific portions of the Testimony as to which protection is sought within 30 days following receipt of the deposition transcript. In circumstances where portions of the deposition Testimony are designated for protection, the transcript pages containing "Highly Confidential" Information may be separately bound by the court reporter, who must affix to the top of each page the legend "Highly Confidential," as instructed by the Designating Party. c. For Information produced in some form other than Documents, and for any other tangible items, including, without limitation, compact discs or DVDs, the Designating Party must affix in a prominent place on the exterior of the container or containers in which the 3 American LegalNet, Inc. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Information or item is stored the legend "Highly Confidential." If only portions of the Information or item warrant protection, the Designating Party, to the extent practicable, shall identify the "Highly Confidential" portions. 5. The inadvertent production by any of the undersigned Parties or non-Parties to the Proceedings of any Document, Testimony or Information during discovery in this P
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