On October 05, 2018 a
Stipulation,Agreement
was filed
involving a dispute between
Hill, Lisa,
and
Quaid Harley-Davidson, Inc. A California Corporation,
for Business Tort/Unfair Business Practice Unlimited
in the District Court of San Bernardino County.
Preview
SUPERIOR COI RT LIFOR dlE1
COUNTY O SAN FsrRNARDINO
1 SAN 3ERNAi C 1PJ UISTRIC f
NOV 21 2019
2
3 7v
By s
s
eF Y
q
r5
T N
6
THE SUPERIOR COURT FOR THE STATE OF CALIFORNIA
C 7
z FOR THE COUNTY OF SAN BERNARDiNO
g
9 LISA HILL an individual on behalf of herself Case No CIV DS 1326573
the proposed class es
all others similarly
10 situated and on behalf of the general public
CLASS ACTION
11 Plaintiff
STIPULATED AMENDED
12
PROTECTIVE ORDER REGARDING
v
CONFIDENTIAL INFORMATION
13 QUAID HARLEY DAVIDSON INC a AND
California corporation and DOES 1 through 10
14 inclusive
ORDER T IEREON
15 Defendants Unli nited Civil Case
16
Complaint Filed 10 OS 2018
FAC Filed 3 4 2019
1
SAC Filed 5 22 2019
1g
Assigned for all purposes to the Honorable
Wilfred J Schneider
19
20 IT IS HEREBY STIPULATED by and between the parties that the following amended
21
provisions and conditions shall govern the production of documents and information in this action
1
22
When used in this Protective Order the word information means all written
23 material videotapes live action film and all otl er tangible items whether produced as hard copy
website computer diskette CD ROM or otherwise
24
2
25 In response to discovery in this inatter the parties may identify materials that they
26 consider proprietary and competitively sensitive and that they wisl to protect from dissemination
27
outside this litigation Additionally the parties may produce infonnation fi om their
28 manufacturers suppliers customers or affiliated companies in which such company or person has
1
8 AMENDED PROTECTIVE ORDER RE CONFIDENTIAL INFORMATION
1
a uthorized to designate as coufidential This Order shall control the disclosure and dissemination
2
of such documents and information and shall apply to all parties in this action and to other
3 persons as described herein
4 3
The parties shall designate material as confidential only after determining that the
5 material contains a trade secret or other confidential research development or commercial
6
information or is otherwise considered confidential under applicable law including California
7 Civil Code 3426 1 whicl provides
8
Trade secret means information including a formula pattern compilation
program device method technique or process that
9
1 Derives independent econoznic value actual or potential
10
from not being generally known to the public or to other persons
who can obtain econom c value fi om its disclosure or use and
11
2 Is the subject of efforts that are reasonable under the
12
circumstances to maintain its secrecy
13
This information includes con dential and proprietary information and documents or
14
things which concern reflect embody or constitute the foregoing and may include but shall not
15
be liinited to correspondence memoranda notes deposition transcripts and exhibits plans
16 specifications blueprints drawings price lists figures
sales nancial information customer lists
17
test reports test procedures and test manuals hereinafter Confidential Information
18 4
In responding to written discovery any party the party producing Confidential
19 Information is to as the
referred
Producing Party may designate any portion of their response
20
which contains trade secret or other confidential research development or commercial
21
information or information otherwise considered confidential under applicable law by marking the
22
material in a manner which will not interfere with its legibility with the words This document is
23 subject to a Protective Order in Hill Qz aid Ha Davidson Inc
v
ley or Confidential or similar
24
designation Said designation shall apply to all copies prints or all documents marlced
25
confidential and shall make all such documents suUject to this Protective Order However in so
26 designating materials as Confidential the parties shall as sparing as possible in their
27 Confidential Information designation
28
2
AMENDED PROTECTNE ORDER RE CONFIDENTIAL INFORMATION
Document Filed Date
November 21, 2019
Case Filing Date
October 05, 2018
Category
Business Tort/Unfair Business Practice Unlimited
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
SUPERIOR COI RT LIFOR dlE1 COUNTY O SAN FsrRNARDINO 1 SAN 3ERNAi C 1PJ UISTRIC f NOV 21 2019 2 3 7v By s s eF Y q r5 T N 6 THE SUPERIOR COURT FOR THE STATE OF CALIFORNIA C 7 z FOR THE COUNTY OF SAN BERNARDiNO g 9 LISA HILL an individual on behalf of herself Case No CIV DS 1326573 the proposed class es all others similarly 10 situated and on behalf of the general public CLASS ACTION 11 Plaintiff STIPULATED AMENDED 12 PROTECTIVE ORDER REGARDING v CONFIDENTIAL INFORMATION 13 QUAID HARLEY DAVIDSON INC a AND California corporation and DOES 1 through 10 14 inclusive ORDER T IEREON 15 Defendants Unli nited Civil Case 16 Complaint Filed 10 OS 2018 FAC Filed 3 4 2019 1 SAC Filed 5 22 2019 1g Assigned for all purposes to the Honorable Wilfred J Schneider 19 20 IT IS HEREBY STIPULATED by and between the parties that the following amended 21 provisions and conditions shall govern the production of documents and information in this action 1 22 When used in this Protective Order the word information means all written 23 material videotapes live action film and all otl er tangible items whether produced as hard copy website computer diskette CD ROM or otherwise 24 2 25 In response to discovery in this inatter the parties may identify materials that they 26 consider proprietary and competitively sensitive and that they wisl to protect from dissemination 27 outside this litigation Additionally the parties may produce infonnation fi om their 28 manufacturers suppliers customers or affiliated companies in which such company or person has 1 8 AMENDED PROTECTIVE ORDER RE CONFIDENTIAL INFORMATION 1 a uthorized to designate as coufidential This Order shall control the disclosure and dissemination 2 of such documents and information and shall apply to all parties in this action and to other 3 persons as described herein 4 3 The parties shall designate material as confidential only after determining that the 5 material contains a trade secret or other confidential research development or commercial 6 information or is otherwise considered confidential under applicable law including California 7 Civil Code 3426 1 whicl provides 8 Trade secret means information including a formula pattern compilation program device method technique or process that 9 1 Derives independent econoznic value actual or potential 10 from not being generally known to the public or to other persons who can obtain econom c value fi om its disclosure or use and 11 2 Is the subject of efforts that are reasonable under the 12 circumstances to maintain its secrecy 13 This information includes con dential and proprietary information and documents or 14 things which concern reflect embody or constitute the foregoing and may include but shall not 15 be liinited to correspondence memoranda notes deposition transcripts and exhibits plans 16 specifications blueprints drawings price lists figures sales nancial information customer lists 17 test reports test procedures and test manuals hereinafter Confidential Information 18 4 In responding to written discovery any party the party producing Confidential 19 Information is to as the referred Producing Party may designate any portion of their response 20 which contains trade secret or other confidential research development or commercial 21 information or information otherwise considered confidential under applicable law by marking the 22 material in a manner which will not interfere with its legibility with the words This document is 23 subject to a Protective Order in Hill Qz aid Ha Davidson Inc v ley or Confidential or similar 24 designation Said designation shall apply to all copies prints or all documents marlced 25 confidential and shall make all such documents suUject to this Protective Order However in so 26 designating materials as Confidential the parties shall as sparing as possible in their 27 Confidential Information designation 28 2 AMENDED PROTECTNE ORDER RE CONFIDENTIAL INFORMATION