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MetroPCS v. A2Z Connection LLC

United States District Court, D. Nevada

April 12, 2018

METROPCS, a brand of T-MOBILE USA, INC., a Delaware Corporation, Plaintiff,
v.
A2Z CONNECTION, LLC, a Nevada limited liability corporation; A2Z LLC, a Nevada limited liability corporation; AMIR QURESHI a/k/a AMIER QURESHI, a/k/a AMIER I. QURESHI, a/k/a AMIER F. QURESHI, SR.; ASIM QURESHI a/k/a ALEX QURESHI, a/k/a AZIM QURESHI a/k/a AZIM DeDREAM, and SEHER QURESHI, Defendants.

          Amanda R. Jesteadt, Karl O. Riley, SNELL & WILMER L.L.P., James B. Baldinger, Stacey K. Sutton. CARLTON FIELDS JORDEN BURT, P.A. Attorneys for Metro PCS.

          Adam J. Breeden BREEDEN & ASSOCIATES, PLLC Attorney for Defendants.

          STIPULATED PROTECTIVE ORDER REGARDING THE HANDLING OF CONFIDENTIAL INFORMATION

          CARL W. HOFFMAN UNITED STATES MAGISTRATE JUDGE

         Pursuant to Federal Rules of Civil Procedure 26(c) and 69 and upon stipulation and agreement by and between the respective counsel for the Parties, which include Plaintiff MetroPCS, a brand of T-Mobile USA, Inc. (“MetroPCS” or “Plaintiff”) and Defendants A2Z Connection, LLC, A2Z LLC, Asim Qureshi, and Seher Qureshi (collectively, “Defendants”) (together, the “Parties”), and for good cause shown, IT IS HEREBY ORDERED that this Protective Order shall control the disclosure, dissemination, and use of confidential information in this lawsuit:

         1. Scope of Order. This Order shall govern the production, use, and disclosure of all information and materials produced by the Parties in response to any post judgment discovery request in this action (including, but not limited to, documents, interrogatory answers, responses to requests to admit and deposition transcripts and exhibits), all information contained in those materials, all information and materials produced by the Parties pursuant to Rules 26(a) and 69(b) of the Federal Rules of Civil Procedure, and all copies, excerpts, or summaries of those materials (collectively, “Discovery Material”).

         2. Designation of Confidential Discovery Material. A Party may, in good faith, designate as “CONFIDENTIAL” and therefore subject to the protections and requirements of this Order, Discovery Material that consists of or includes non-public information that would reasonably be subject to protection under applicable statute, rule or precedent, including:

a. Information and materials that a Party reasonably believes contain or refer to information that is not generally available to or accessible by the general public, that a Party believes contain or refer to confidential information of third parties, information protected by a statute, rule or regulation, trade secrets or other confidential business information including, but not limited to, research, development, business or financial information, or other confidential and/or proprietary analyses, company guidelines, policies and procedures, market analyses, business valuations, audit reports, commercial information, sales information, customer proprietary network information, customer lists and non-public agreements with third parties, materials memorializing or relating to sensitive third party business relationships;
b. Discovery Material reflecting or relating to financial data including, but not limited to, documents concerning revenues, costs, and profits; and
c. Discovery Material that, if disclosed to a business competitor, would tend to damage the Party's competitive position.

         3. Method of Designating Material as CONFIDENTIAL.

         a. Designation of confidential Discovery Material shall be made by stamping the legend “CONFIDENTIAL” on the document. Multi-paged Discovery Material must be stamped “CONFIDENTIAL” on each page so designated. If the Discovery Material cannot be so labeled, it must be designated CONFIDENTIAL in some other conspicuous manner. Any confidential designation that is inadvertently omitted during document production may be corrected by written notice to counsel of the Party receiving the document.

         b. If originals or other non-bates stamped Discovery Material are made available to a Party for inspection, the entirety of such material shall be treated as CONFIDENTIAL pursuant to this Order until such time as it is copied and the CONFIDENTIAL legend can be affixed to the copies of any confidential Discovery Material. The Party producing such Discovery Material shall designate as CONFIDENTIAL any confidential Discovery Material selected for copying by the receiving Party by stamping or requesting in writing the stamping of the legend “CONFIDENTIAL” on the copies of such Discovery Material. All original or other non-bates stamped Discovery Material and information contained therein that is reviewed, but not selected for copying, by the receiving Party shall be treated as CONFIDENTIAL pursuant to this Order.

         c. Information conveyed or discussed in deposition testimony or legal proceeding, in court or before an arbitrator, may be designated CONFIDENTIAL by an indication on the record at the deposition or legal proceeding, or by written notice of the specific pages and lines of testimony that are CONFIDENTIAL within twenty-one (21) days after receipt of the transcript of the deposition or legal proceeding. Each Party shall attach a copy of any such written notice to all copies of the transcript within its possession, custody, or control. While the twenty-one (21) day period is pending, the Parties will treat the transcript and the information contained therein as CONFIDENTIAL in accordance with this Order.

         d. Banking and financial records obtained directly by Plaintiff with an authorization from Defendants shall be deemed designated CONFIDENTIAL without the need to take the steps set forth above in Paragraph 3(a).

         4. Failure to Designate Material as CONFIDENTIAL. The failure of a party to designate information or documents as “CONFIDENTIAL” in accordance with this Order, and the failure to object to such a designation, shall not preclude a Party at a later time from subsequently designating or objecting to the designation of such information or documents as “CONFIDENTIAL.” The Parties understand and acknowledge that a Party's failure to designate information or documents as “CONFIDENTIAL” relieves the other party of any obligation of confidentiality until such a designation is made. Promptly after any such designation, the receiving Party shall mark with the appropriate legend ...


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