Filed: Oct. 23, 2013
Latest Update: Oct. 23, 2013
Summary: STIPULATION AND [PROPOSED] ORDER TO AMEND PROTECTIVE ORDER RICHARD SEEBORG, District Judge. WHEREAS, on December 3, 2012, the Court entered a Stipulated Protective Order (Docket No. 93); and WHEREAS, the Stipulated Protective Order governs discovery and confidentiality in the above-captioned action for all named parties; WHEREAS, third parties have been served and will be served with discovery that calls for the production of Confidential Information; and WHEREAS, a third party has re
Summary: STIPULATION AND [PROPOSED] ORDER TO AMEND PROTECTIVE ORDER RICHARD SEEBORG, District Judge. WHEREAS, on December 3, 2012, the Court entered a Stipulated Protective Order (Docket No. 93); and WHEREAS, the Stipulated Protective Order governs discovery and confidentiality in the above-captioned action for all named parties; WHEREAS, third parties have been served and will be served with discovery that calls for the production of Confidential Information; and WHEREAS, a third party has req..
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STIPULATION AND [PROPOSED] ORDER TO AMEND PROTECTIVE ORDER
RICHARD SEEBORG, District Judge.
WHEREAS, on December 3, 2012, the Court entered a Stipulated Protective Order (Docket No. 93); and
WHEREAS, the Stipulated Protective Order governs discovery and confidentiality in the above-captioned action for all named parties;
WHEREAS, third parties have been served and will be served with discovery that calls for the production of Confidential Information; and
WHEREAS, a third party has requested a modification of the Stipulated Protective Order that the third party deems necessary to ensure that its Confidential Information is adequately protected;
Defendant/Counterclaim Plaintiff Creative Nail Design, Inc. ("CND"), Plaintiff Mycone Dental Supply Co., Inc. ("Keystone"), and Counterclaim Defendants Young Nails, Inc., Cacee, Inc. and Nail Systems International ("Counterclaim Defendants"), by and through their respective counsel, hereby stipulate and agree, subject to the Court's approval, that the Stipulated Protective Order shall be amended as follows:
2.2 "CONFIDENTIAL" Information or Items: information (regardless of how it is generated, stored or maintained) or tangible things (a) that contain private or confidential personal information, or (b) that contain information received in confidence from third parties, or (c) which the producing party otherwise believes in good faith to be entitled to protection under Rule 26(c)(1)(G) of the Federal Rules of Civil Procedure.
2.8 "HIGHLY CONFIDENTIAL — OUTSIDE ATTORNEYS' EYES ONLY" Information or Items: extremely sensitive "Confidential" Information or Items pertaining to (a) technical materials, methods, or processes that are or could be used by a producing party to manufacture its products, the disclosure of which to another Party or Non-Party would create a substantial risk of serious harm that could not be avoided by less restrictive means or (b) trade secrets, competitively sensitive technical, marketing, financial, sales or other confidential business information.
IT IS ST STIPULATED THROUGH COUNSEL OF RECORD.
IT IS SO ORDERED.
