How does Varian spell "fascism"?
Take a look at Varian's proposed order regarding taking the deposition of their "damage" witness:
STIPULATION AND [PROPOSED] ORDER RE DEPOSITION OF JEFF WRIGHT
Plaintiffs Varian Medical Systems, Inc., Varian Semiconductor Equipment Associates, Inc., Susan B. Felch, and George Zdasiuk (“Plaintiffs”), defendant Michelangelo Delfino, and defendant Mary Day, by and through their respective counsel of record, hereby stipulate and agree as follows:
(1) The deposition of Jeff Wright (both individually and as a designee of Varian Medical Systems, Inc.), as well as any documents marked as exhibits at the deposition of Person(s) Most Knowledgeable served by defendant Mary Day, on or about December 22, 2000, shall be designated “Confidential - Attorneys’ Eyes Only.”
(2) The documents referred to in paragraph 1 hereof may be designated by marking each page with a legend reading “Confidential - Attorneys’ Eyes Only” The transcript of Mr. Wright’s deposition, including any exhibits hereto, shall be conspicuously marked on the cover page with the legend “Confidential - Attorneys’ Eyes Only.”
(3) Discovery materials designated “Confidential - Attorneys’ Eyes Only” pursuant to this stipulation may not be reviewed by or the contents disclosed to, or in whole or in part, including summary form, any person other than Glynn Falcon and Randall Widmann, except with the written consent of Plaintiffs’ counsel or by order of the Court. In particular, such materials may not be reviewed by or the contents disclosed to defendants Delfino and/or Day. The only persons who may be present at the deposition of Mr. Wright other than the witness are Messr.s Falcon and Widmann, Plaintiffs’ counsel, and the court reporter.
(4) Discovery materials designated “Confidential - Attorneys’ Eyes Only” pursuant to this stipulation may not be submitted to any court, including but not limited to the Superior Court in this action or to any appellate court, except (1) pursuant to tan order providing that the materials may be filed under seal r (2) following de-designation of the materials in writing by Plaintiffs’ counsel or by order of the Court.
(5) Counsel for Delfino and Day shall maintain all discovery materials designated “Confidential - Attorneys’ Eyes Only” pursuant to this stipulation in a secure location such that the materials cannot be accessed by persons not authorized to review them, including but not limited to Delfino and Day.
(6) Delfino or Day may request that material designated “Confidential - Attorneys’ Eyes Only” pursuant to this stipulation be de-desginated by submitting their request in writing t Plaintiffs’ counsel via facsimile. If Plaintiffs’ do not agree to de-designate the material in question with five (5) business days, Delfino or Day may move the Court for an order de-designating the material. The motion may be brought on shortened time, subject to the Court’s and counsel’s availability.
(7)If the Court orders the de-designation of any discovery material designated “Confidential - Attorneys’ Eyes Only” pursuant to this stipulation, the de-designation shall not take effect if, with fourteen (14) days after notice of the order, Plaintiffs file a petition for a writ of mandamus with the Court of Appeals requesting reversal of the order, in which case the order shall not take effect until all appeals have been exhausted and the order upheld.
(8) Within thirty (30) days after the conclusion of this litigation, including all appeals, counsel for Delfino and Day shall return to Plaintiffs’ counsel all copies of materials designated “Confidential - Attorneys’ Eyes Only” pursuant to this stipulation, along with all copies of any documents that excerpt, summarize, paraphrase, or otherwise reveal the contents of such materials.
(9) If discovery material designated “Confidential - Attorneys’ Eyes Only” pursuant to this stipulation is disclosed to any unauthorized person, Delfino, Day, and/or their respective counsel shall immediately bring such fact to the attention of Plaintiffs’ counsel and shall make every effort to retrieve the material from the unauthorized person(s) as quickly as possible and to prevent any further unauthorized disclosures.
(10) If Delfino, Day, or either of their respective counsel receives a subpoena or other process or order to produce discovery material designated “Confidential - Attorneys’ Eyes Only” pursuant to this stipulation, they shall immediately notify Plaintiffs’ counsel of that fact and give Plaintiffs’ counsel a reasonable opportunity to object to and/or quash the subpoena, process or order before producing the discovery material in response thereto.
(11) The prohibitions herein on disclosure of discovery material designated “Confidential - Attorneys’ Eyes Only” shall survive the termination of this action.
IT IS SO STIPULATED.”
[PROPOSED] ORDER
”Based on the stipulation of the parties, and for good cause shown, the Court hereby ORDERS that the above terms shall govern the deposition of Jeff Wright and the production of documents by Varian Medical Systems, Inc. in response to Notice of Taking Deposition of Person(s) Most Knowledgeable served by defendant Mary Day on or about December 22, 2000. The above terms shall not be modified except by subsequent written order of the Court.
IT IS SO ORDERED”
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