PURPOSES AND LIMITATIONS. 16 17 Discovery in this action is likely to involve production of confidential and 18 private information for which special protection may be warranted. Accordingly, 19 the parties hereby stipulate to and petition the Court to enter the following
PURPOSES AND LIMITATIONS. 17 Discovery in this action is likely to involve production of confidential, proprietary, or 18 private information for which special protection may be warranted. Accordingly, the parties 19 hereby stipulate to and petition the court to enter the following Stipulated Protective Order. The 20 parties acknowledge that this agreement is consistent with LCR 26(c). It does not confer blanket 21 protection on all disclosures or responses to discovery, the protection it affords from public 22 disclosure and use extends only to the limited information or items that are entitled to 23 confidential treatment under the applicable legal principles, and it does not presumptively entitle 24 parties to file confidential information under seal.
PURPOSES AND LIMITATIONS. 2 Disclosure and discovery activity in this action are likely to involve production 3 of confidential, proprietary, or private information for which special protection from 4 public disclosure and from use for any purpose other than prosecuting this litigation 5 may be warranted. This information includes, but is not limited to, private information 6 concerning various aspects of the employment of Defendant Taco Bell Corp.’s current 7 and former employees, including but not limited to, rates of compensation and 8 taxation and/or other withholdings, job history (including promotions and demotions), 9 hours of work, work locations, employee purchase records (to the extent such records 10 exist) and personnel documents/information, such as, dates of hire and termination, 11 on-duty meal period agreements, disciplinary actions related to misuse of employee 12 discounts, time keeping, meal and rest periods and/or attendance, and proprietary and 13 private information relating to policies and practices, financial and business 14 information and methodologies at Defendant Taco Bell Corp.’s current and former 16 interests of non-party employees, which Defendant Taco Bell Corp. is bound to 17 protect by California law, such private and proprietary information requires protection 18 beyond mere agreement of the parties. Accordingly, the parties hereby stipulate to and 19 petition the court to enter the following Stipulated Protective Order. 20 The parties acknowledge that this Order does not confer blanket protections on 21 all disclosures or responses to discovery and that the protection it affords from public 22 disclosure and use extends only to the limited information or items that are entitled to 23 confidential treatment under the applicable legal principles. The parties further 24 acknowledge, as set forth in Section 12.3, below, that this Stipulated Protective Order 25 does not entitle them to file confidential information under seal; Local Rule 141 sets 26 forth the procedures that must be followed and the standards that will be applied when 27 a party seeks permission from the court to file material under seal.
PURPOSES AND LIMITATIONS. 10 Apple Protected Material designated under the terms of this Rider shall be used by the 11 Parties solely for the purpose of providing notice to and verifying and paying the recovery amount 12 owed to each member of the Settlement Class. Apple Protected Material shall not be used directly 13 or indirectly for any other purpose whatsoever.
PURPOSES AND LIMITATIONS. 2 Disclosure and discovery activity in this action are likely to involve production of documents and/or information of a sensitive, private and confidential nature for which the parties wish to protect the confidentiality of such documents or information while ensuring that discovery may be pursued with a minimum of delay and expense. Accordingly, the Parties xxxxxx stipulate to and petition the Court to enter the following Stipulated Confidentiality Agreement and Agreed [Proposed] Protective Order (hereinafter “Protective Order”). The Parties acknowledge that this Protective Order does not confer blanket protections on all disclosures or responses to discovery and that the protection it affords from public disclosure and use extends only to the limited information or items that are entitled to confidential treatment under the applicable legal principles. The Parties further acknowledge, as set forth in Section 12.3, below, that this Protective Order does not entitle them to file confidential information under seal. This Stipulation is being entered into by the parties to govern documents and data shared during the settlement discovery and negotiations processes and potentially the monitoring process. Should litigation resume, the parties agree to revisit the terms of this Agreement.
PURPOSES AND LIMITATIONS. Discovery in this action is likely to involve production of confidential, proprietary, or private information for which special protection from public disclosure and from use for any purpose other than prosecuting this litigation may be warranted. Accordingly, the Parties hereby stipulate to the following Stipulated Protective Agreement and Order (“Stipulated Protective Order”). The parties acknowledge that this agreement is consistent with Fed. R. Civ. P. 26(c). This agreement does not confer blanket protection on all disclosures or responses to discovery. This agreement affords protection from public disclosure and use that extends only to the limited information or items that are entitled to confidential treatment under the applicable legal principles, and it does not presumptively entitle parties to file confidential material or information under seal.
PURPOSES AND LIMITATIONS. Discovery in this action is likely to involve production of confidential, proprietary, or private information for which special protection from public disclosure and from use for any purpose other than prosecuting this litigation may be warranted. Accordingly, the parties hereby stipulate to and petition the Court to enter the following
PURPOSES AND LIMITATIONS. 2 Disclosure and discovery activity in this action are likely to involve production of 3 confidential, proprietary, or private information for which special protection from public disclosure 4 and from use for any purpose other than prosecuting this litigation may be warranted. Accordingly, 5 the parties hereby stipulate to and petition the court to enter the following Stipulated Protective
PURPOSES AND LIMITATIONS. 17 Discovery in this action is likely to involve production of confidential, 18 proprietary, or private information for which special protection may be warranted.
PURPOSES AND LIMITATIONS. 14 Discovery in this action is likely to involve production of confidential, 15 proprietary or private information for which special protection from public 16 disclosure and from use for any purpose other than prosecuting this litigation may 17 be warranted. Accordingly, the Parties hereby stipulate to and petition the Court to 18 enter the following Stipulated Protective Order. The Parties acknowledge that this 19 Order does not confer blanket protections on all disclosures or responses to 20 discovery and that the protection it affords from public disclosure and use extends 21 only to the limited information or items that are entitled to confidential treatment 22 under the applicable legal principles. 23 24 B. GOOD CAUSE 25 Pursuant to FED. R. CIV. P. 26(c)(7), good cause exists for entry of this 26 Protective Order because the Parties to this action (1) either have sought or might 27 seek the discovery of certain information in this action that the Parties believe is 28 sensitive or confidential, (2) believe that unrestricted disclosure or dissemination of 1 such information could violate their right to financial privacy or cause them business 2 or commercial injury, (3) desire an efficient and practicable means to designate such 3 information as confidential and control its disclosure or dissemination, and (4) have 4 agreed to such means as set forth herein. Specifically, this action involves a dispute 5 concerning a mortgage loan serviced by Wells Fargo and will likely require the 6 production of personally identifiable information of Xxxxxxxx; the financial 7 information of Xxxxxxxx; and confidential, non-public, and/or trade secret 8 information of Xxxxx Fargo. 9
