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AC Media Group, LLC v. Sprocket Media, Inc.

United States District Court, D. Nevada

February 16, 2017

AC MEDIA GROUP, LLC, a Nevada limited liability corporation; and CREEL PRINTING & PUBLISHING CO., INC., a Nevada corporation; Plaintiffs,
v.
SPROCKET MEDIA INC., a foreign corporation; and KYLE H. WALKENHORST, an individual, Defendants.

          Patrick Byrne, Michael Paretti, SNELL & WILMER L.L.P Attorneys for Plaintiffs AC Media Group, LLC and Creel Printing & Publishing Co., Inc.

          Justin P. Karczag, Attorneys for Defendants Sprocket Media Inc., and Kyle H. Walkenhorst

          Andrew P. Gordon Judge

          STIPULATED PROTECTIVE ORDER AND CONFIDENTIALITY AGREEMENT

          George W. Foley Magistrate Judge

         WHEREAS, Plaintiffs AC Media Group, LLC and Creel Printing & Publishing Co., Inc. (collectively “Plaintiffs”) and Defendants Sprocket Media Inc. and Kyle H. Walkenhorst (collectively “Defendants”) (individually, the “Party, ” and collectively, the “Parties”) recognize that, pursuant to discovery or otherwise during the course of the lawsuit between Plaintiffs and Defendants (“this Action”), the Parties may be required to disclose financial information, trade secrets, or other confidential and proprietary information within the meaning of Fed.R.Civ.P. 26(c);

         WHEREAS the Parties, through Counsel, have stipulated to this Stipulated Protective Order and Confidentiality Agreement (“Protective Order”) pursuant to Fed.R.Civ.P. 26(c) to prevent disclosure of such confidential and proprietary information; and

         WHEREAS the Parties agree that this Protective Order shall be effective and binding throughout all proceedings relating to this Action, and shall apply to all discovery in this Action, including discovery of non-parties, who shall be entitled to designate documents or testimony in accordance with this Protective Order.

         IT IS ORDERED AS FOLLOWS:

         1. All information that has been provided by the Parties in the course of this Action or will be produced by the Parties in the course of this Action shall be used solely for the purpose of preparation and trial of this Action and for no other purpose whatsoever, and shall not be disclosed to any person except in accordance with the terms of this Protective Order.

         2. A Party or Parties who are producing, using or disclosing (“Producing Party”) information or documents (as defined by Fed.R.Civ.P. 34(a)) or any summaries or compilations derived there from, including but not limited to productions of documents, answers to interrogatories, responses to requests for admissions, deposition testimony, exhibits, and all other discovery, regardless of format (“Discovery Material”) may designate the Discovery Material produced, used or disclosed in connection with this Action as “CONFIDENTIAL, ” subject to the protections and requirements of this Protective Order, if so designated in writing to the other Parties by affixing, or causing to be affixed, such designation to any document or piece of information, or orally if recorded as part of a deposition, pursuant to the terms of this Protective Order. The Parties are in the process of discussing the use of a “CONFIDENTIAL ATTORNEYS' EYES ONLY” designation. The Parties reserve the right to submit an amended stipulated protective order and confidentiality agreement or submit briefing regarding an Attorneys' Eyes Only designation at a later date.

         3. Any Discovery Material designated as “CONFIDENTIAL” shall be maintained as confidential, not to be disclosed, and shall be used by the Party or Parties receiving such Discovery Material (“Receiving Party”) solely in connection with this Action and shall not be disclosed to anyone other than:

A. The Court, including court personnel, any court exercising appellate jurisdiction over this Action, and stenographers transcribing a deposition;
B. Employees for a Receiving Party to whom it is necessary that the material be shown for purposes of this Action and who have signed a Declaration in the form of Exhibit A attached;
C. Outside counsel of record who are signatories to this Protective Order for a Receiving Party and employees of such attorneys and law firms to whom it is necessary that the ...

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