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LLC v. Amazon.Com.Ndvc, LLC

United States District Court, D. Nevada

January 10, 2018

1600 EAST NEWLANDS DRIVE, LLC, a Nevada limited liability company, Plaintiff,
v.
AMAZON.COM.NVDC, LLC, a Delaware limited liability company f/k/a AMAZON.COM.NVDC, INC.; AMAZON.COM, INC., a Delaware Corporation; and DOES I-X; and ROE CORPORATIONS XI-XX, inclusive, Defendants.

          Brian C. Lake (AZ Bar #020543) (admitted pro hac vice) Aaron Welling (Nev. Bar #13418) PERKINS COIE LLP David R. Koch (Nev. Bar #8830) Koch & Scow LLC Attorneys for Defendants Amazon.com. NVDC, LLC and Amazon.com, Inc.

          Jessica L. Woelfel (Nev. Bar #1885) Lisa Wiltshire Alstead (Nev. Bar #10470) McDONALD CARANO LLP Attorneys for Plaintiff 1600 East Newlands Drive, LLC

          PROTECTIVE ORDER

          HON. WILLIAM G. COBB JUDGE.

         Having received and considered the parties' Stipulation for Protective Order pursuant to Federal Rule of Civil Procedure 26(c), and good cause appearing, IT IS HEREBY ORDERED that the following procedures shall apply to confidential documents and information produced or disclosed in this case:

         I. CONFIDENTIAL INFORMATION.

         A. Definition of “Confidential”.

         “Confidential Information” means any non-public testimony, information, documents or data that the designating party or third-party discovery respondent in good faith believes contains confidential, sensitive, business, personal or proprietary information. Confidential Information may include any document or information produced, disclosed or exchanged in accordance with the Federal Rules of Civil Procedure or by agreement, including, without limitation, initial and supplemental disclosures, interrogatory answers, responses to requests for admission, responses to subpoenas, responses to requests for production and any other documents or information produced in response to discovery requests, or contained in deposition testimony and exhibits, pleadings, motions, briefs, affidavits, declarations and any other discovery or disclosure made in this litigation.

         Confidential Information does not include (1) any information which a party lawfully possessed, obtained or developed other than through discovery in this action; or (2) any information that is or becomes available to the public through no act, or failure to act, attributable to the receiving party or its counsel.

         B. Designation of “Confidential” Information.

         The parties and third-party discovery respondents may designate Confidential Information in this action by stamping, labeling or otherwise appropriately marking the documents or information as “CONFIDENTIAL-SUBJECT TO PROTECTIVE ORDER”. A party must designate information as Confidential prior to producing the information to the other party. A party may remedy an inadvertent failure to designate produced documents or other materials by providing a supplemental notice and designation to the other party within thirty (30) business days after the producing party first learns that it inadvertently failed to designate the information as Confidential. Following such notice, the identified materials shall be fully subject to this Protective Order; however, there shall be no sanction for any use or disclosure of such information prior to the supplemental notice and designation.

         With respect to discovery responses that contain or constitute Confidential Information, the responding party shall include a “CONFIDENTIAL-SUBJECT TO PROTECTIVE ORDER” designation, as appropriate, on the first page of the discovery response, and on each page of the document containing Confidential Information.

         Any party may designate any portion of a deposition as Confidential by notifying the other parties on the record during the deposition or in writing within thirty (30) calendar days after receipt of the deposition transcript. The deposition transcript shall be treated as “Confidential” during this thirty-day period. Each court reporter and videographer participating in any deposition in this action shall be informed of, and provided with a copy of, this Protective Order. When directed, each court reporter shall designate those portions of the deposition transcript(s) with the legend “CONFIDENTIAL -SUBJECT TO PROTECTIVE ORDER” as appropriate.

         C. Related Documents.

         The terms of this Protective Order shall extend to and protect (1) all copies, extracts and complete or partial summaries prepared from documents or information designated as Confidential; (2) portions of deposition transcripts that contain or reflect the content of any documents or information designated as Confidential; (3) portions of briefs, memoranda or any other writing filed with the Court and any exhibits thereto that contain or reflect the content of any documents or information designated as Confidential; and (4) designated testimony taken at a hearing or other proceedings that contains or reflects the content of any documents or information designated as Confidential.

         II. CHALLENGES TO DESIGNATIONS.

         If a party challenges the confidentiality designations of any Confidential Information, the party shall provide the designating party with written notice of its challenge. The parties shall meet and confer in good faith within seven (7) calendar days of the notice and utilize their best efforts to attempt to resolve the dispute. If the parties are unable to resolve the dispute within seven (7) calendar days of the meet and confer, the party challenging the confidentiality designation may seek appropriate relief from the Court. The designating party bears the burden of proving that the Confidentiality designation is appropriate under the circumstances.

         If a party challenging the designation of information as Confidential seeks relief from the Court, the protections of this Protective Order will continue to apply to the ...


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