![]() The Court has revised the protective order to exclude this language, and the types of 18 information eligible for protection under this order shall include only those specified categories of 19 information. This catchall language does not comply with Local Rule 17 141.1(c)(1). However, when describing the types of information eligible for protection, 10 which Local Rule 141.1(c)(1) requires, the stipulation states: 11 15 he parties anticipate that, given the nature of the claims and defenses in this Action, discovery will likely include highly proprietary and sensitive business information, the disclosure of which poses a substantial risk of harm to the parties’ proprietary and financial interests, including but not limited to (i) the operation and functioning of the parties’ manufacturing and distribution systems (ii) trade secret and business strategy information pertaining to the parties’ product lines and marketing efforts (iii) sensitive data regarding customers, potential customers, sales, and third-party business partners and (iv) other proprietary technical or commercially sensitive information that is not otherwise available to the public 16 (ECF No. 33.) The 2 stipulation largely complies with Local Rule 141.1(c), which requires that every proposed protective 3 order contain the following provisions: 4 5 6 Holland & Knight LLP 50 California Street, 28th Floor San Francisco, CA 94111 Tel: 415.743.6900 Fax: 415.743.6910 7 (1) A description of the types of information eligible for protection under the order, with the description provided in general terms sufficient to reveal the nature of the information (e.g., customer list, formula for soda, diary of a troubled child) (2) A showing of particularized need for protection as to each category of information proposed to be covered by the order and 8 (3) A showing as to why the need for protection should be addressed by a court order, as opposed to a private agreement between or among the parties. d/b/a Audi Fresno and Porsche Fresno, a California corporation and CHRISTOPHER JOHN WILSON, an individual and resident of the State of California, Defendants 27 28 1 STIPULATED PROTECTIVE ORDER CASE NO: 1:21-CV-00970-JLT-EPG 1 On March 18, 2022, the parties filed this Joint Stipulated Protective Order. ![]() d/b/a BMW Fresno, a California corporation CJ’S ROAD TO LEMANS CORP. _ TEMPLETON MARSH, LTD., Intervenor, 21 22 Case No. d/b/a Audi Fresno and Porsche Fresno, a California corporation and CHRISTOPHER JOHN WILSON, an individual and resident of the State of California, Defendants. ![]() Kappes (SBN 303454) 50 California Street, Suite 2800 San Francisco, CA 94111 Telephone: 41 Fax: 41 E-mail: Attorneys for Plaintiff FOUNDATION AUTO HOLDINGS, LLC 8 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA FRESNO DIVISION Holland & Knight LLP 50 California Street, 28th Floor San Francisco, CA 94111 Tel: 415.743.6900 Fax: 415.743.6910 9 10 11 12 FOUNDATION AUTO HOLDINGS, LLC, a Delaware limited liability company, Plaintiff, 13 14 15 16 17 18 19 20 23 24 25 26 JOINT STIPULATED PROTECTIVE ORDER vs. 1 2 3 4 5 6 7 HOLLAND & KNIGHT LLP John Kern (SBN 206001) David I.
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