Opinion
Case No. 2:10-CV-00389-WBS-KJN
09-29-2011
ROBINS, KAPLAN, MILLER & CIRESI L.L.P. Michael A. Geibelson Amy M. Churan ATTORNEY FOR PLAINTIFF BEST BUY STORES, L.P. GREENBERG TRAURIG, LLP Howard Jeruchimowitz ATTORNEY FOR DEFENDANT MANTECA LIFESTYLE CENTER, LLC
Michael A. Geibelson, Bar No. 179970
Amy M. Churan, Bar No. 216932
ROBINS, KAPLAN, MILLER & CIRESI L.L.P.
Attorneys for Plaintiff
BEST BUY STORES, L.P.
JOINT STIPULATION TO AMEND THE
NOVEMBER 12, 2010 PROTECTIVE ORDER
Plaintiff BEST BUY STORES, L.P., ("Best Buy") and Defendant MANTECA LIFESTYLE CENTER, LLC ("Manteca), collectively referred to as the "Parties" by and through their respective undersigned counsel, hereby stipulate and agree as follows:
IT IS HEREBY STIPULATED AND AGREED by the stipulating parties that:
1. Documents produced by third-party MSTSD, Inc., will be covered under the protections of the "Revised Stipulated Protective Order" dated November 12, 2010, attached hereto as Exhibit "A".
2. Further, the following language will be deemed to be part of the Revised Stipulated Protective Order as category "(f)" under Section 1 entitled: PURPOSES AND LIMITATIONS as follows:
f). Documents produced by non-parties that include internal design and construction documents related to the planning, design and development of the Manteca Lifestyle Center project. These records are unique and highly proprietary and protection of this information as Highly Confidential is very important to the competitive position of the respective non-party. Protection by way of a court order is appropriate so that there is a prompt mechanism to extract any designated documents from public disclosure, whether inadvertent or otherwise.
ROBINS, KAPLAN, MILLER & CIRESI L.L.P.
Michael A. Geibelson
Amy M. Churan
ATTORNEY FOR PLAINTIFF
BEST BUY STORES, L.P.
GREENBERG TRAURIG, LLP
Howard Jeruchimowitz
ATTORNEY FOR DEFENDANT
MANTECA LIFESTYLE CENTER, LLC
PURSUANT TO STIPULATION, IT IS SO ORDERED.
KENDALL J. NEWMAN
UNITED STATES MAGISTRATE JUDGE