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LHF Productions Inc. v. Kabala

United States District Court, D. Nevada

July 3, 2018

LHF PRODUCTIONS, INC., a Nevada Corporation, Plaintiff,
v.
BRIAN KABALA, et. al., Defendants. AND RELATED COUNTERCLAIMS

          F. Christopher Austin, Esq. WEIDE & MILLER, LTD. Attorneys for Counter-Defendant LHF Productions, Inc.

          Lisa L. Clay Jonathan D. Blum, Esq. KOLESAR & LEATHAM Attorney for Counter-Plaintiff Brian Kabala.

          [PROPOSED] STIPULATED PROTECTIVE ORDER.

         Counter-Plaintiff BRIAN KABALA and Counter-Defendant LHF PRODUCTIONS, INC. by and through the undersigned counsel, hereby stipulate and agree to the entry of the following Stipulated Protective Order. Accordingly, it is ORDERED:

         1. Scope. All materials produced or adduced in the course of discovery, including initial disclosures, responses to discovery requests, deposition testimony and exhibits, and information derived directly therefrom (hereinafter collectively “documents”), shall be subject to this Order concerning Confidential Information as defined below. This Order is subject to the Local Rules of this District and the Federal Rules of Civil Procedure on matters of procedure and calculation of time periods. For any source code produced in the action, a separate protective order regarding source code shall exclusively apply thereto.

         2. Confidential Information. As used in this Order, “Confidential Information” means information designated as “CONFIDENTIAL-SUBJECT TO PROTECTIVE ORDER” by the producing party that falls within one or more of the following categories: (a) information prohibited from disclosure by statute; (b) information that reveals trade secrets; (c) research, technical, commercial or financial information that the party has maintained as confidential (i.e. any information that has made publicly available not in violation of this Order or another order or agreement to keep such information confidential in any fashion, whether in another matter, online, or in any other context, is specifically excluded from the confidential protections of this Order); (d) medical information concerning any individual; (e) personal identity information; (f) income tax returns (including attached schedules and forms), W-2 forms and 1099 forms; or (g) personnel or employment records of a person who is not a party to the case. Information or documents that have been made available to the public not in violation of this Order or another order or agreement to keep such information confidential and/or have been or will be filed as part of any motion, pleading or document filed with this Court may not be designated as Confidential Information. Additionally, the term “trade secret” shall not be used to designate as Confidential any statement made or document filed in any pleading, declaration or other document filed with this Court prior to the entry of this Order unless such documents were designated as “trade secret” or “Confidential” in such prior disclosures.

         3. Designation.

a. A party may designate a document as Confidential Information for protection under this Order if the document falls within the categories set forth in Section 2 herein above by placing or affixing the words “CONFIDENTIAL- SUBJECT TO PROTECTIVE ORDER” on the document and on all copies in a manner that will not interfere with the legibility of the document. As used in this Order, “copies” includes electronic images, duplicates, extracts, summaries or descriptions that contain the Confidential Information. The marking “CONFIDENTIAL -SUBJECT TO PROTECTIVE ORDER” shall be applied prior to or at the time the documents are produced or disclosed. Applying the marking “CONFIDENTIAL -SUBJECT TO PROTECTIVE ORDER” to a document does not mean that the document has any status or protection by statute or otherwise except to the extent and for the purposes of this Order. Any copies that are made of any documents marked “CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER” shall also be so marked, except that indices, electronic databases or lists of documents that do not contain substantial portions or images of the text of marked documents and do not otherwise disclose the substance of the Confidential Information are not required to be marked.
b. The designation of a document as Confidential Information is a certification by an attorney or a party appearing pro se that the document contains Confidential Information as defined in this order.

         4. Depositions. Deposition testimony is protected by this Order only if designated as CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER” on the record at the time the testimony is taken. Such designation shall be specific as to the portions that contain Confidential Information. Deposition testimony so designated shall be treated as Confidential Information protected by this Order. Within fourteen days after delivery of the transcript, a designating party may serve a Notice of Designation to all parties of record identifying as Confidential specific additional portions of the transcript that were not previously designated Confidential Information, and thereafter those portions identified shall be protected under this Order.

         5. General Protections. Confidential Information shall not be used or disclosed by the parties, counsel for the parties or any other persons identified in the following subparagraph (a) for any purpose whatsoever other than in this litigation, including any appeal thereof.

a. Limited Third-Party Disclosures. The parties and counsel for the parties shall not disclose or permit the disclosure of any Confidential Information to any third person or entity except as set forth in the following subparagraphs (i)-(ix). Subject to these requirements, the following categories of persons may be allowed to review Confidential Information:
i. Counsel. Counsel for the parties and employees of counsel who have responsibility for the action;
ii. Parties. Individual parties and their employees but only to the extent counsel determines in good faith that the employee's assistance is reasonably necessary to the conduct of the ...

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