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LLC v. Zmodo Technology Corporation Ltd.

United States District Court, D. Nevada

April 6, 2018

EY K365, LLC, Plaintiff,
v.
ZMODO TECHNOLOGY CORPORATION LIMITED, Defendant. EY K365, LLC, Plaintiff,
v.
ZMODO TECHNOLOGY CORPORATION LIMITED, Defendant.

          BROWN HYATT FARBER SCHRECK LLP Michael D. Rounds, Esq., Gary R. Sorden, Tim Craddock, KLEMCHUK LLP Attorneys for Plaintiff Eyetalk365, LLC

          AKERMAN LLP Melanie D. Morgan, Tenesa Scaturro Powell, Thomas G. Pasternak, John M. Schafer (admitted pro hac vice) Attorneys for Defendant Zmodo Technology Corporation Limited

          PROTECTIVE ORDER

         It is hereby ORDERED by the Court that the following restrictions and procedures shall apply to certain information, documents and excerpts from documents supplied by the parties to each other in response to discovery requests:

         1. Counsel for any party may designate any document or information contained in a document as confidential if counsel determines, in good faith, that such designation is necessary to protect the interests of the client. Information and documents designated by a party as confidential will be labeled “CONFIDENTIAL - PRODUCED PURSUANT TO PROTECTIVE ORDER.” “Confidential” information or documents may be referred to collectively as “confidential information.”

         2. Access to any documents marked “CONFIDENTIAL - PRODUCED PURSUANT TO PROTECTIVE ORDER” shall be limited to:

a. The requesting party and counsel;
b. Employees of such counsel assigned to and necessary to assist in the litigation;
c. Consultants or experts to the extent deemed necessary by counsel;
d. Any person from whom testimony is taken or is to be taken, except that such a person may only be shown confidential information during and in preparation for his/her testimony and may not retain the confidential information; and
e. The Court or the jury at trial or as exhibits to motions.

         3. Counsel for any party may designate any documents or information contained in any document as “HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY” if counsel determines, in good faith, that such designation is necessary to protect the information within the scope of Fed.R.Civ.P. 26(c), including information that relates to, among other things, trade secrets, pending patent applications, research and development or other highly sensitive technical information, or highly-sensitive business-related financial information including abstracts, summaries, or information derived therefrom.

         4. Access to any documents marked “HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY” shall be limited to:

a. The Court and its staff;
b. Attorneys, their law firms, their employees and agents, and their ...

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