On June 27, 2019 a
Stipulation,Agreement
was filed
involving a dispute between
Binder Ed,
Summers Robert,
Cenveo Worldwide Limited A Delaware Corporation,
Cenveo Worldwilde Limited A Delaware Corporation,
and
Lithographix Inc.,
Minguez Ariel,
Summers Robert,
for Other Breach of Contract/Warranty (not fraud or negligence) (General Jurisdiction)
in the District Court of Los Angeles County.
Preview
1 POLSINELLI LLP
Todd M. Malynn (SBN 181595)
2 tmalynn@polsinelli.com
Keia James Atkinson (SBN 316649)
3 ccole@polsinelli.com
2049 Century Park East, Suite 2900
4 Los Angeles, CA 90067
Telephone: (310) 556-1801
5 Facsimile: (310) 556-1802
6 Attorney for Plaintiff
CENVEO WORLDWIDE LIMITED
7
8
SUPERIOR COURT OF THE STATE OF CALIFORNIA
9
FOR THE COUNTY OF LOS ANGELES-CENTRAL DISTRICT
10
11 CENVEO WORLDWIDE LIMITED, a CASE NO. 19STCV22712
Delaware corporation,
12 STIPULATION AND [PROPOSED]
Plaintiff, PROTECTIVE ORDER
13
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Electronically Received 03/10/2020 01:13 PM
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The parties agree that during the course of discovery it may be necessary to disclose certain
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confidential information relating to the subject matter of this action, including but not limited to
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0 20 production of alleged trade secret information. The parties agree that certain categories of such
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21 information should be treated as confidential, protected from disclosure outside this litigation, used
22 only for purposes of prosecuting or defending this action and any appeals, and, in certain instances
23 as specifically designated, for attorney's eyes only. The parties agreed that a protective order is
24 necessary and narrowly tailored way to preserve the confidential nature of the information, a
25 compelling end. Accordingly, the parties jointly request entry of this proposed Protective Order to
26 limit the disclosure, dissemination and use of certain identified categories of confidential
27 information.
28 The parties assert in support of their request that protection of the identified categories of
STIPULATION AND [PROPOSED] PROTECTIVE ORDER
72551116.1
72716906.2
Document Filed Date
March 17, 2020
Case Filing Date
June 27, 2019
Category
Other Breach of Contract/Warranty (not fraud or negligence) (General Jurisdiction)
Status
Request for Dismissal - Before Trial not following ADR or more than 60 days since ADR 10/05/2020
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Preview
1 POLSINELLI LLP Todd M. Malynn (SBN 181595) 2 tmalynn@polsinelli.com Keia James Atkinson (SBN 316649) 3 ccole@polsinelli.com 2049 Century Park East, Suite 2900 4 Los Angeles, CA 90067 Telephone: (310) 556-1801 5 Facsimile: (310) 556-1802 6 Attorney for Plaintiff CENVEO WORLDWIDE LIMITED 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 FOR THE COUNTY OF LOS ANGELES-CENTRAL DISTRICT 10 11 CENVEO WORLDWIDE LIMITED, a CASE NO. 19STCV22712 Delaware corporation, 12 STIPULATION AND [PROPOSED] Plaintiff, PROTECTIVE ORDER 13 V. 0 0 14 Electronically Received 03/10/2020 01:13 PM 0) N ROBERT SUMMERS, an individual, and 2 ·- t-- (0 15 DOES 1-10, inclusive, ::::,0 (/) 0 .... 0.. ...., O'l C 16 Defendants. ::J ._ wo ' ~ <( ~ = ~ - u: Q) '- (/) U'. 17 .5: (ti~ U'. .!!!. a.. ~c The parties agree that during the course of discovery it may be necessary to disclose certain - 0 i::' a.. ::::, C: Q) C: .... <( (/) 0 er. ._ 18 confidential information relating to the subject matter of this action, including but not limited to (_) ....J 19 0) 'It' 0 20 production of alleged trade secret information. The parties agree that certain categories of such N 21 information should be treated as confidential, protected from disclosure outside this litigation, used 22 only for purposes of prosecuting or defending this action and any appeals, and, in certain instances 23 as specifically designated, for attorney's eyes only. The parties agreed that a protective order is 24 necessary and narrowly tailored way to preserve the confidential nature of the information, a 25 compelling end. Accordingly, the parties jointly request entry of this proposed Protective Order to 26 limit the disclosure, dissemination and use of certain identified categories of confidential 27 information. 28 The parties assert in support of their request that protection of the identified categories of STIPULATION AND [PROPOSED] PROTECTIVE ORDER 72551116.1 72716906.2