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Baker v. Apttus Corp.

United States District Court, D. Nevada

November 28, 2017

ELIZABETH BAKER, Plaintiff,
v.
APTTUS CORPORATION, a Delaware Corporation; DOES l-X, inclusive, Defendant.

          Lisa A. McClane Attorneys for Defendant Apttus Corporation

          Michael J. Morrison Attorneys for Plaintiff Elizabeth Baker

          STIPULATED PROTECTIVE ORDER GOVERNING CONFIDENTIAL INFORMATION

         Pursuant to Federal Rule of Civil Procedure 26(c), Plaintiff ELIZABETH BAKER ("Baker") and Defendant Apttus Corporation ("Apttus"), (collectively, the "Parties"), by and through their respective counsel of record, hereby stipulate and agree that the handling of confidential material in these proceedings shall be governed by the provisions set for the below.

         I. APPLICATION.

         This Protective Order shall govern the designation and handling of "Confidential Information" (defined below) produced in discovery in this litigation, whether by voluntary production or disclosure or in response to any formal discovery procedure, including designation and handling of nonpublic information of a confidential nature. This Protective Order does not affect any party's obligations under the Civil Rules to produce documents as required by the rules of discovery or an order of the Court. The purpose of this Protective Order is to facilitate the handling of nonpublic information of a confidential, private, or proprietary nature.

         If a designating party files material concerning "Confidential Information" in court and does not attempt to file it under seal, or if material is otherwise already part of the public record as of the entry of this Protective Order, the material in question will not be subject to this Protective Order. The mere filing of material containing "Confidential" by the non-designating party does not remove the material from the protection of this Protective Order. If a non-designating party files material marked "Confidential Information" by another party without first seeking permission of the court to file the same under seal, the non-filing party may seek appropriate relief to ensure protection under this Protective Order.

         II. DEFINITIONS.

         A. "Confidential Information" means: personal information of current or former employees of Defendant (such as addresses, telephone numbers, birth dates, marital status, dependent status and/or discipline or counseling received from Defendant); financial information, including, but not limited to, payroll records, tax returns, financial statements, banking records, and i electronic data containing financial information and/or compensation or pay plans or scales; confidential proprietary and/or competitive business information; trade secrets, including but not limited to confidential nonpublic information regarding actual and/or prospective sales, accounts, products and marketing; witness statements and/or investigation reports; performance projections; business strategies; and confidential proprietary information about affiliates, parents, subsidiaries and third-parties with whom the parties to this action have or have had business relationships. "Confidential Information" includes, without limitation, any document, information, or material that the producing party or protected person reasonably believes not to be in the public domain and reasonably believes contains information to which an individual or company has an established and legitimate right to privacy or confidentiality.

         B. "Disclosed" is used in its broadest sense and includes, inter alia, directly or indirectly shown, divulged, revealed, produced, described, transmitted or otherwise communicated, in whole or in part.

         C. "Discovery Materials)" means any documents, answers to interrogatories, responses to requests for admission, deposition testimony, deposition transcripts and exhibits, other responses to requests for information and/or written information, whether produced voluntarily or involuntarily, in response to discovery requests in this litigation by any party.

         D. "Document" is defined as the term is used in Federal Rule of Civil Procedure 34.

         E. "Highly Confidential - Attorneys' Eyes Only" Material means that the Discovery Materials designated as Confidential Information shall be reserved for viewing by attorney(s) only, due to the sensitive nature of the material.

         F. "Under Seal" is defined as sealing confidential documents consistent with the procedure set forth in LR 10-5 of the Local Rules for United States District Court, District of Nevada (the "Court"). In the event that the Court publishes a new procedure for the filing of documents under seal, the Parties will follow said published procedure.

         III. Types of Materials that May be Designated as Confidential or "Highly Confidential -Attorneys' Eves Only"

         Any Discovery Material or other documents, information, or materials may be designated by a producing party as Confidential or "Highly Confidential - Attorneys' Eyes Only" under this Order. The assertion of this designation of "Confidential" shall constitute a representation to the Court that counsel for the producing party or protected person believes in good faith that the material so designated constitutes Confidential Information as defined in this Order. The assertion of this designation of "Highly Confidential - Attorneys' Eyes Only" shall constitute a representation to the Court that counsel for the producing party or protected person believes in good faith that the material so designated constitutes Confidential Information as defined in this Order, which may only be viewed by attorney(s) in this case. Except with the prior written consent of the producing party or by Court order or as otherwise compelled by force of law, no Discovery Materials or other documents, information, or materials stamped "Confidential'' or "Highly Confidential - Attorneys' Eyes Only" may be disclosed to any person except as permitted in Section IV below.

         IV. Designation of Discovery Materials ...


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