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McCart-Pollak v. Etkin

United States District Court, D. Nevada

January 22, 2018

SHANA LEE MCCART-POLLAK, Plaintiff,
v.
EDWARD ETKIN, an individual; LAW OFFICES OF EDWARD ETKIN, ESQ. PC a New York business entity; DOES I Through X; ROE BUSINESS ENTITIES I through X, inclusive, Defendants.

          PROTECTIVE ORDER

         Pursuant to the Motion for Entry of Protective Order filed by Defendants Edward Etkin and Law Offices of Edward Etkin, Esq. PC, and good cause appearing, it is HEREBY ORDERED that the following Protective Order is entered in this case:

         1. Any party or non-party may designate as confidential (by stamping the relevant page with the word "Confidential" or as otherwise set forth herein) any document or response to discovery which that party or non-party considers in good faith to contain information involving trade secrets, or confidential business or financial information, subject to protection under the Federal Rules of Civil Procedure or Nevada law (hereinafter referred to as "Confidential Information"). Where a document or response consists of more than one page, the first page and each page on which confidential information appears shall be so designated.

         2. Any party may designate as confidential - attorney's eyes only (by stamping the relevant page with the word "Attorney's Eyes Only" or as otherwise set forth herein) any document or response to discovery which constitutes part of the United States Patent and Trademark Office patent application file wrapper / file history (hereinafter referred to as "Attorney's Eyes Only Information") and which is produced subsequent to December 8, 2017. Where a document or response consists of more than one page, the first page and each page on which confidential information appears shall be so designated.

         3. A party or non-party may designate information disclosed during a deposition or in response to written discovery as "confidential" by so indicating in said response or on the record at the deposition and requesting the preparation of a separate transcript of such material. Additionally a party or non-party may designate in writing, within twenty (20) days after receipt of said responses or of the deposition transcript for which the designation is proposed, that specific pages of the transcript and/or specific responses be treated as "confidential" information. Any other party may object to such proposal, in writing or on the record. Upon such objection, the parties shall follow the procedures described in paragraph 10 below. After any designation made according to the procedure set forth in this paragraph, the designated documents or information shall be treated according to the designation until the matter is resolved according to the procedures described in paragraph 10 below, and counsel for all parties shall be responsible for marking all previously unmarked copies of the designated material in their possession or control with the specified designation.

         4. All information produced or exchanged in the course of this case (other than information that is publicly available) shall be used by the party or parties to whom the information is produced solely for the purpose of this case, unless the parties agree otherwise.

         5. Except with the prior written consent of other parties, or upon prior order of this Court obtained upon notice to opposing counsel, Confidential Information shall not be disclosed to any person other than:

(a) counsel for the respective parties to this litigation, including co-counsel retained for this litigation;
(b) employees of such counsel;
(c) the parties, including any officer or employee of a party, to the extent deemed necessary by counsel for the prosecution or defense of this litigation;
(d) consultants or expert witnesses retained for the prosecution or defense of this litigation, provided that each such person shall execute a copy of the Certification annexed to this Order as Exhibit "A" (which shall be retained by counsel to the party so disclosing the Confidential Information and made available for inspection by opposing counsel during the pendency or after the termination of the action only upon good cause shown and upon order of the Court) before being shown or given any Confidential Information;
(e) any authors or recipients of the Confidential Information;
(f) the Court, Court personnel, and court reporters; and
(g) witnesses (other than persons described in paragraph 4(e)). A witness shall sign the Certification before being shown a confidential document. Confidential Information may be disclosed to a witness who will not sign the Certification only in a deposition at which the party who designated the Confidential Information is represented or has been given notice that Confidential Information shall be designated "Confidential" pursuant to paragraph 2 above. Witnesses shown Confidential Information shall not be allowed to retain copies.

         6. Except with the prior written consent of other parties, or upon prior order of this Court obtained upon notice to opposing counsel, Attorney's Eyes Only ...


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