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On Demand Direct Response, LLC v. Mccart-Pollak

United States District Court, D. Nevada

May 23, 2018

ON DEMAND DIRECT RESPONSE, LLC DISTRICT OF NEVADA AND ON DEMAND DIRECT RESPONSE III, LLC, Plaintiffs,
v.
SHANA LEE MCCART-POLLAK D/B/A LOL BUDDIES ENTERPRISES Defendant. ALL RELATED ACTIONS

          DICKINSON WRIGHT PLLC MICHAEL N. FEDER, GABRIEL A. BLUMBERG Attorneys for Kevin Harrington

          PARRY & PFAU Zachariah B. Parry Attorneys for Shana Lee McCart-Pollak

          STIPULATED CONFIDENTIALITY AGREEMENT AND PROTECTIVE ORDER

         Third-Party Defendant Kevin Harrington (“Harrington”), by and through his counsel, the law firm of Dickinson Wright PLLC, and Third-Party Plaintiff Shana Lee McCart-Pollak (“Shana”), by and through her counsel, the firm of Parry & Pfau, stipulate that discourse and discovery activity in the above-captioned action (the “Action”) are likely to involve the production of confidential, proprietary, or private information for which special protection from public disclosure and use for any purpose other than prosecuting this litigation would be warranted. Accordingly, the Parties stipulate to the following Stipulated Confidentiality and Protective Order (“Protective Order”). The Parties hereby STIPULATE as follows:

         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 confidential personal or business 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 of which confidential information appears shall be so designated.

         2. Any party may designate as confidential-attorney 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 contains sensitive, highly confidential, non-public information, consisting of trade secrets, financial records, or other highly confidential documents the disclosure of which to the Receiving Parties or non-parties (other than the Designating Party) would be likely to cause competitive or business injury to the Designating Party (other than injury to the Designating Party's position in this Action) and/or compromise the security, protection and/or safety of the Designating Party's personal or business interests (herein after referred to as “Attorney's Eyes Only 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 designated.

         3. A party or non-party may designate information disclosed during deposition or in response to a written discovery as Confidential or Attorney's Eyes Only 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 the 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 or Attorney's Eyes Only information. Any other party may object to such proposal, in writing or on the record, and upon such objection, the parties shall follow the procedure set forth in paragraphs 8 and 9 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 paragraphs 8 and 9 below, and counsel for all parties shall be responsible for marking all previously unmarked copies of the designated materials in their possession or control with the specified designation.

         4. All Confidential Information and Attorney's Eyes Only Information produced or exchanged in the course of this case (other than information that is publicly available) shall only 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 the other party, 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 in this litigation;
b. Employees of such counsel
c. The parties, including any officer or employee of 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 ...

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