Jane Foerster v. Patenthealth LLC et al
Filing
39
PROTECTIVE ORDER by Magistrate Judge John E. McDermott re Stipulation for Protective Order 37 . [See Order for details.] (san)
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UNITED STATES DISTRICT COURT
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CENTRAL DISTRICT OF CALIFORNIA
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JANE FOERSTER, on behalf of herself
and all others similarly situated,
Plaintiff,
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v.
PATENTHEALTH, LLC, an Ohio
corporation, and DOES 1-10, inclusive,
Case No. CV10 9936 AHM (JEMx)
[PROPOSED] SUPPLEMENTAL
PROTECTIVE ORER
Judge: Hon. John E. McDermott
Place: Courtroom C, 8th Floor
Defendants.
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[PROPOSED] SUPPLEMENTAL PROTECTIVE ORDER
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SUPPLEMENTAL PROTECTIVE ORDER
Upon consideration of the Stipulation re: Supplemental Protective Order, filed
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on September 20, 2011 by Plaintiff Jane Foerster ("Plaintiff") and Defendant
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PatentHEALTH, LLC ("Defendant") (together the "Parties," and each individually, a
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"Party"), the Court GRANTS the Supplemental Protective Order as follows:
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1.
The Supplemental Protective Order shall govern all CONFIDENTIAL
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FINANCIAL INFORMATION produced or disclosed in the Litigation by Defendant
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to Plaintiff's Counsel of Record.
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2.
The term "CONFIDENTIAL FINANCIAL INFORMATION" shall
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mean and include non-public confidential information of or in the possession of the
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Defendant that Defendant may disclose to Plaintiff's Counsel of Record in connection
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with any settlement discussion and as to which Defendant considers in good faith to
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contain financial information that may be protected from public disclosure under the
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Federal Rules of Civil Procedure or California law.
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3.
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persons:
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The term "Plaintiff's Counsel of Record" shall mean the following
a.
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Natalie Finkelman Bennett, Esq., of Shepherd Finkleman Miller &
Shah LLP;
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b.
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Scott R. Shepherd, Esq., of Shepherd Finkleman Miller & Shah
LLP;
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c.
James C. Shah, Esq., of Shepherd Finkleman Miller & Shah LLP;
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d.
Behram V. Parekh, Esq., of Kirtland & Packard LLP;
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e.
Heather Marie Peterseon, Esq., of Kirtland & Packard LLP; and
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f.
Michael L. Kelly, Esq., of Kirtland & Packard LLP;
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4.
Capitalized terms used, but not defined herein, shall have the same
meanings ascribed to them in the Protective Order.
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Any Discovery Materials containing or including any CONFIDENTIAL
FINANCIAL INFORMATION shall be designated as such by Defendant by stamping
-1[PROPOSED] SUPPLEMENTAL PROTECTIVE ORDER
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or labeling it with, or otherwise affixing thereto, the following legend on every page
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of the Document:
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"CONFIDENTIAL FINANCIAL INFORMATION"
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All CONFIDENTIAL FINANCIAL INFORMATION not reduced to
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documentary or tangible form or which cannot be conveniently designated in the
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manner set forth above shall be designated by Defendant by informing one or more of
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Plaintiff's Counsel of Record in writing of the appropriate designation.
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7.
Plaintiff's Counsel of Record may view CONFIDENTIAL FINANCIAL
INFORMATION for the sole purpose of confirming Defendant's current financial
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condition in order to facilitate the settlement discussions that occur on or before
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October 18, 2011 between Plaintiff and Defendant.
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8.
Plaintiff's Counsel of Record shall maintain all CONFIDENTIAL
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FINANCIAL INFORMATION in the strictest of confidence and, except as expressly
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provided herein, under no circumstances may CONFIDENTIAL FINANCIAL
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INFORMATION (i) be used for any purpose by any person, (ii) be disclosed by
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Plaintiff's Counsel of Record to any person, including Plaintiff, Independent Experts
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or Consultants, the Court, or to any of Plaintiff's Representatives, or (iii) be copied,
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photographed, imaged, summarized, distributed, or otherwise referenced.
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9.
All CONFIDENTIAL FINANCIAL INFORMATION shall be returned
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to Defendant (i) immediately following termination or conclusion of settlement
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discussions, or (ii) by close of business on October 18, 2011, whichever is earlier, and
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Plaintiff's Counsel of Record shall certify in writing that it has done so.
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IT IS SO ORDERED.
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Dated: September 27, 2011
/s/John E. McDermott
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HON. JOHN E. MCDERMOTT
United States Magistrate Judge
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-2[PROPOSED] SUPPLEMENTAL PROTECTIVE ORDER
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