1 Any Attorney or Party

Any Street
2 Any Town, CA 55555

3 714-555-5555

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Any Attorney or Party
5

8
Superior Court of the State of California
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For the County of ________________
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11 Any Plaintiff, ) Case No.

)
12 Plaintiff, ) CONFIDENTIALITY AGREEMENT AND
) STIPULATED PROTECTIVE ORDER
13 vs. )
)
14 Any Defendant, and DOES 1-5 )
)
15 Defendants. )
)
16 )
)
17 )

18 CONFIDENTIALITY AGREEMENT AND STIPULATED PROTECTIVE ORDER

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To adequately protect material entitled to be kept confidential, and to ensure that protection is
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afforded only to material so entitled, it is stipulated by and between Plaintiff, ___________________,
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Defendant, ______________, and the LAW OFFICES OF ____________, Counsel for Plaintiff, and
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23 ___________________, Counsel for Defendant as follows:

24 1. All confidential information and/or trade secrets, documents or information provided

25
in any depositions, answers to interrogatories, and other discovery material obtained or produced now
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or after the date of the Order through any method of discovery in this litigation and the confidential
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information and/or trade secrets contained therein (hereinafter referred to as Discovery Materials)
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CONFIDENTIALITY AGREEMENT AND STIPULATED PROTECTIVE ORDER
 1 shall be subject to this Order and may be used solely for the purposes of this and related Litigation
2 (with Related Litigation defined, for purpose of this Stipulated Confidentiality Order, as litigation
3
in any forum, in which each of the following are among the parties: (______________, and
4
_________________), and for no other purpose, unless ordered otherwise by the Court or by an
5

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arbitrator or judge or Court of competent jurisdiction in another proceeding for good cause shown.

7 Discovery Material shall not be used by the parties or by any consultant the parties may retain, to

8 gain, directly or indirectly, any competitive or commercial advantage or benefit.

9
All Discovery Material shall be marked in such a way as to identify these materials as
10
produced by a particular party in this litigation. Such marking need occur only prior to delivery of
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copies of Discovery Materials to the opposing party and not prior to inspection.
12

13 2. Discovery Materials may be disclosed by: (a) the parties; (b) counsel for the parties in

14 this litigation who have appeared in this and related Litigation or are in-house counsel for the parties;
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(c) the partners, associates, secretaries, paralegal assistants and employees of such an attorney to the
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extent reasonably necessary to render professional services in the litigation; (d) persons with prior
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personal knowledge of the information contained in the Discovery Material; (e) the Court and Court
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19 reporters transcribing trial or deposition testimony taken in this case and notarizing officers, (f) any

20 other person designated by the Court in the interest of justice, upon such terms as the Court may
21
deem proper, which terms shall include that such person has agreed to be bound by this Order by
22
signing a certificate of confidentiality in the form attached to this Order, and (g) persons not parties or
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directors, officers, agents, or employees of any party who are expressly retained to assist such partys
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25 counsel in the preparation of this action for trial, including, but not limited to, independent auditors,

26 outside accountants, statisticians, economists, expert witnesses and other consultants, and the
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employees of such persons, provided, however, that such persons (i) are not actual competitors or a
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CONFIDENTIALITY AGREEMENT AND STIPULATED PROTECTIVE ORDER
 1 party, employees or consultants of an actual competitor of a party, or owners of a controlling interest
2 in an actual competitor of a party, and (ii) agree to be bound by this Order by signing a certificate of
3
confidentiality in the form attached to this Order.
4
3. Discovery Materials containing confidential information and/or trade secrets the
5

6
disclosure of which would substantially affect the commercial interest of a party may be designated

7 by such party as CONFIDENTIAL.

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To purchase the entire document visit:
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10 https://legaldocspro.myshopify.com/products/sample-confidentiality-
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agreement-and-stipulated-protective-order-for-california
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CONFIDENTIALITY AGREEMENT AND STIPULATED PROTECTIVE ORDER