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Boston Dental Group, LLC v. Affordable Care, LLC

United States District Court, D. Nevada

January 11, 2017

BOSTON DENTAL GROUP, LLC, a Nevada limited liability company, Plaintiff,
v.
AFFORDABLE CARE, LLC, a North Carolina limited liability company, Defendant. AFFORDABLE CARE, LLC, a North Carolina limited liability company, Counterclaimant,
v.
BOSTON DENTAL GROUP, LLC, a Nevada limited liability company, Counterdefendant.

          KOLESAR & LEATHAM Scott R. Cook, ESQ Nevada Bar No. 005265 Jonathan D. Blum, Esq. Nevada Bar No. 009515 -and- SCOTT J. SLAVICK, ESQ. (IL Bar No. 6256681) - Pro Hac Vice SHARON E. CALHOUN, ESQ. (IL Bar No. 6294212) - Pro Hac Vice BARACK FERRAZZANO KIRSCHBAUM & NAGELBERG LLP Attorneys for Defendant/Counterclaimant Affordable Care, LLC

          MICHAEL R. MUSHKIN & ASSOCIATES P.C. MICHAEL R. MUSHKIN, ESQ. Nevada Bar No. 002421 Mark Borghese, Esq. Nevada Bar No. 006231 BORGHESE LEGAL, LTD. Las Vegas, Nevada 89145 Attorneys for Plaintiff/Counter Defendant Boston Dental Group, LLC

          STIPULATED PROTECTIVE ORDER

         BOSTON DENTAL GROUP, LLC and AFFORDABLE CARE, LLC (collectively, the "PARTIES"), through their respective counsel and subject to the Court's approval, hereby stipulate and agree as follows, pursuant to Fed.R.Civ.P. 26(c), for the purpose of facilitating the exchange of documents and information without involving the Court unnecessarily in the process.

         IT is STIPULATED AND AGREED by and between the PARTIES, acting through their counsel as follows:

         1. This Protective Order shall apply to all documents, materials, and information, including, without limitation, documents disclosed or produced, answers to interrogatories, responses to requests for admission, deposition testimony, and other information disclosed pursuant to the disclosure or discovery duties created by the Federal Rules of Civil Procedure.

         2. As used in this Protective Order, "document" is defined as set forth in Rule 34(a)(1)(A) of the Federal Rules of Civil Procedure. A draft or non-identical copy is a separate document within the meaning of this term.

         3. In order to be protected under this Protective Order, a party to the above-captioned action (the "Action"), or a third party responding to a subpoena issued in connection with this Action, must designate information as "CONFIDENTIAL INFORMATION" or "ATTORNEYS' EYES ONLY INFORMATION."

         4. As used herein, CONFIDENTIAL INFORMATION shall include information and documents in whatever format any party or third party disclosing information or documents in this Action (a "Disclosing Party") reasonably believes contains or discloses the Disclosing Party's financial, personnel, proprietary, confidential, or competitively sensitive information; trade secrets; or other sensitive or currently valuable information that is (a) unavailable to the public, (b) not readily determinable from public sources, (c) generally treated as confidential by the Disclosing Party, and (d) of such a nature that its disclosure reasonably could have an adverse impact on the Disclosing Party.

         5. As used herein, ATTORNEYS' EYES ONLY INFORMATION shall mean that CONFIDENTIAL INFORMATION containing information that, in the good faith determination of the Disclosing Party, is of such a nature that identifiable harm may result to the Disclosing Party or any other individual or entity other than the Receiving Party, whether a party or a nonparty to this Action, if that CONFIDENTIAL INFORMATION is disclosed to the other party to this Action.

         6. A Disclosing Party shall make such designations only as to materials or testimony that the Disclosing Party believes in good faith contains CONFIDENTIAL INFORMATION or ATTORNEYS' EYES ONLY INFORMATION. The failure of any party receiving the CONFIDENTIAL INFORMATION or ATTORNEYS' EYES ONLY INFORMATION (a "Receiving Party") to object to the designation as to any material or testimony shall not be deemed the Receiving Party's admission that such material or testimony constitutes confidential material or is otherwise properly protectable under Fed.R.Civ.P. 26(c), or result in a waiver of any privilege or protection, including, without limitation, the attorney-client privilege, that may apply to such material or testimony. CONFIDENTIAL INFORMATION and ATTORNEYS' EYES ONLY INFORMATION shall be used by the Receiving Party solely for the purpose of conducting this litigation, pursuant to the terms and conditions of this Protective Order, and not for any other purpose whatsoever.

         7. CONFIDENTIAL INFORMATION, other than that CONFIDENTIAL INFORMATION containing information designated as ATTORNEYS' EYES ONLY INFORMATION, without the consent of the Disclosing Party or further Order of the Court, may be disclosed to the following persons only:

a. Attorneys actively working on this Action and the partners, associates, legal assistants, or other employees of such attorneys assisting in the prosecution or defense of the Action;
b. The parties;
c. The Court, including court personnel, court reporters, and persons operating video recording equipment at depositions in the Action (collectively, "Court Personnel");
d. Deponents, trial witnesses, or potential witnesses, if furnished, shown, or disclosed in accordance with Paragraph 10;
e. Expert witnesses or consultants (and their employees), employed or retained by any party or that party's counsel for the purpose of assisting counsel in the investigation, prosecution, or defense of claims in the Action, provided that such information is furnished, shown, or disclosed in accordance with Paragraph 10;
f. Any mediator in the Action; and
g. Other persons by written agreement of the parties or by court order.

         8. Except with the prior written consent of the Disclosing Party or by court order, ATTORNEYS' EYES ONLY INFORMATION shall not be furnished, shown, or disclosed to any person or entity, including directors, officers, or other employees of the Receiving Party, as applicable, except to:

a. Attorneys actively working on the Action and the partners, associates, legal assistants, or other employees of such attorneys assisting in the prosecution or defense of the ...

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