toe) ANN AP, Saas {SBN 178712) [email protected] Nose V. PHO [SBN 291881] 0@ MBssNeR 160 W. Santa Clara Street, Suite 1000 San Jose, California 95113 Telephone: (408) 298-7120 Facsimile: (408) 298-0477 Attorneys for Defendant SAN FRANCISCO SCIENCE FICTION CONVENTIONS, INC. SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SANTA CLARA JONATHAN DEL ARROZ, Case No, 18-CV-334547 Plaintiff, STIPULATED PROTECTIVE ORDER v, SAN FRANCISCO SCIENCE FICTION CONVENTIONS, INC. (“SFSFC") aka “WORLDCON76” David W. Gallaher (2019), President; David W. Clark (2020), Vice President; Lise Detusch Hetrigan (2020), ‘Treasurer, Kevin Standlee (2018), Secretary; Sandra Childress (2019); Bruce Farr (2018), Chair; 2018 SMOF Con Committee; Chery! Morgan (2020); Kevin Roche (2018), Chairs 2018 Worldcon (Worldcon 76) Committee: Cindy Scott (2018); Randy Smith (2019), Chair; New Zealand 2020 Worldcon Agent Committee; Andy Trembley (2020); Jennifer “Raclar” Wylie (2019), Chair; CostumeCon 2021 Organizing Committee: Lori Buschhaum; Susie Rodriguez. and DOES 1 through 30, inclusive Defendants. The patties, by and through their respective attomney of record, hereby stipulate and agree as set forth herein. ‘The parties represent that this litigation does not present any public health or safety concerns and this Order does not deviate from the Model Confidentiality Order published by the STIPULATED PROTECTIVE ORDER ¥VW4d ASoseen0es 1) Santa Clara County Task Force on Complex Litigation Procedures and Technology. In order to protect the confidentiality of confidential information obtained by the parties in connection with this case, the parties hereby agree as follows: Part One: Use of Confidential Materials in Discovery. 1. Any party or non-party may designate as “Confidential Information” (by stamping the relevant page or as otherwise set forth herein) any document or response to discovery which that party or non-party considers in good faith to contain information involving trade secrets, or confidential business or financial information, subject to Rules 8.45, 8.46, 8.47, 8.490, 2.550, 2.551, 2.580, and 2.585 of the California Rules of Court, or under other provisions of California law. Where a document or response consists of more then one page, the first page and each page ‘on which confidential information appears shall be so designated. 2. A party or non-party may designate information disclosed during a deposition or in response to written discovery as “confidential” by so indicating in said responses or on the record at the deposition and requesting the preparation of a separate transcript of such materiel, In addition, a party or non-party may designate in writing, within twenty (20) days after receipt of said responses or of the deposition transcript for which the designation is proposed, that specific pages of the transcript and/or specific responses be treated as “Confidential Information.” Any other party may object to such proposal, in writing or on the record. Upon such objection, the parties shall follow the procedures described in paragraph 8 below. After any designation made according to the procedure set forth in this paragraph, the designated documents or information shall be treated according to the designation until the matter is resolved according to the procedures described in paragraph 8 below, and counsel for all parties shall be responsible for marking all previously unmarked copies of the designated material in their possession or control with the specified designation. 3. All Confidential Information produced or exchanged in the course of this case (not including information that is publicly available) shall be used by the party or parties to whom the {information is produced solely for the purpose of this case, ti 2 Case No. 18.CV-334547 STIPULATED PROTECTIVE ORDERsosacnossn) 25 26 a 28 5. Any persons receiving Confidential Information shall not reveal or discuss such information to or with any person who is not entitled to receive such information, except as set forth herein. 6. _Inconnection with discovery proceedings as to which a party submits Confidential Information, all documents and chamber copies containing Confidential Information which are submitted to the Court shall be filed with the Court in sealed envelopes or other appropriate sealed containers. On the outside of the envelopes, a copy of the first page of the document shall be attached. [f Confidential Information is included in the first page attached to the outside of the envelopes, it may be deleted from the outside copy. The word “CONFIDENTIAL? shall be stamped on the envelope and a statement substantially in the following form shall also be printed on the envelope: “This envelope is sealed pursuant to Order of the Cour, contains Confidential Information and is not to be opened or the contents revealed, except by Order of the Court or agreement by the parties.” 7. A party may designate as "Confidential Information” documents or discovery reterials produced by a non-party by providing written notice to all parties of the relevant document numbers or other identification within thirty (30) days after receiving such documents, or discovery materials, Any perty of non-party may voluntarily disclose to others without restriction any information designated by that party or non-party as Confidential Information, although a document may lose its confidential status if it is made public. 8. Ifa party contends that any material is not entitled to confidential treatment, such party may at any time give written notice to the party or non-party who designated the material. The party or non-party who designated the material shall have twenty-five (25) days from the receipt of such written notice to apply to the Court for an order designating the material as confidential. The party or non-party seeking the order has the burden of establishing that the document is entitled to protection. ut wt 4 Case No, 18-CV-334547 SFIPULATED PROTECTIVE ORDER