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Focalpoint International Inc. v. Dom Rubino Consulting Services Inc.

United States District Court, D. Nevada

July 12, 2018

FOCALPOINT INTERNATIONAL, INC., Plaintiff,
v.
DOM RUBINO CONSULTING SERVICES, INC.; and BIZSTRATPLAN, INC., Defendants.

          MARK E. FERRARIO, ESQ. Nevada Bar No. 1625 JACOB D. BUNDICK, ESQ. Nevada Bar No. 9772 GREENBERG TRAURIG, LLP Counsel for Plaintiff FocalPoint International, Inc.

          LEWIS ROCA ROTHGERBER CHRISTIE LLP DAN R. WAITE, ESQ. Nevada Bar No. 4078 ERIK J. FOLEY, ESQ. Nevada Bar No. 14195 Counsel for Defendants Dom Rubino Consulting Services, Inc. and BizStratPlan, Inc.

          STIPULATED CONFIDENTIALITY AGREEMENT AND PROTECTIVE ORDER

          PEGGY A. LEEN UNITED STATES MAGISTRATE JUDGE

         Plaintiff, FocalPoint International, Inc. (“FocalPoint”), by and through its undersigned counsel of record, and Defendants, Dom Rubino Consulting Services, Inc. and BizStratPlan, Inc. (“Defendants”), by and through their undersigned counsel of record (collectively, the “Parties”), hereby enter into the following Stipulated Confidentiality Agreement and Protective Order (“Protective Order”).

         Based upon the mutual order reflected in this stipulation, the Parties agree as follows:

         1. This Protective Order shall govern all documents, materials, depositions, testimony, transcripts, responses to requests for admissions, interrogatory responses, items, and/or other information obtained or provided through discovery in this action (collectively “Information”) that a Party designates as “Confidential” pursuant to the terms hereof (collectively “Confidential Information”).

         2. Any Party that produces Information in this action and has a good faith and reasonable basis for claiming that such Information constitutes confidential and/or proprietary information may designate such Information as Confidential Information.

a. For documents, materials, or other written Information, a Party shall designate such Information as Confidential Information by stamping or otherwise labeling each page or item containing Confidential Information as “Confidential.”
b. For interrogatories and written discovery, designation shall be made by placing the legend “Confidential” on any page(s) of any answer deemed to contain such confidential information, indicating any portion of such page which does not contain such confidential information. Alternatively, answers deemed to contain confidential information may be bound separately and marked with the appropriate legend.
c. For testimony, a Party shall designate such Information as Confidential Information on the record or within 30 days after receipt of the official transcript. Until the 30-day period has expired, the entire transcript shall be considered “Confidential.” Such Party shall also require the court reporter to label the portion of the transcript containing the information as “Confidential.”
d. A Party's inadvertent or unintentional failure to designate Information as Confidential Information shall not be deemed a waiver in whole or in part of that Party's claim of confidentiality, if the disclosing Party takes prompt action after discovering such omission to notify all Parties in writing that such Information constitutes Confidential Information. However, the Party who received that Information without knowledge of its confidential nature may not be held in violation of this Order for using or disclosing that Information before notification of the inadvertent or unintentional failure to designate that Information as Confidential Information.

         3. The designation of information as Confidential Information pursuant to this Protective Order shall not preclude any Party from disclosing that information to any person who, in the case of a document, appears as the author or as a recipient thereof on the face of the document, or from disclosing that information to any person who has been identified by the designating party (“Designating Party”) as having previously been provided with, or having had access to, the document or the information therein.

         4. In the event a Designating Party elects to produce documents for inspection and the receiving Party desires to inspect them before designating them for copying, the Designating Party need not mark the documents in advance of any such inspection. For purposes of the inspection, and any subsequent inspection of the original documents, all documents produced for inspection shall be deemed to be designated as Confidential Information. Thereafter, upon selection of specified documents for copying by the receiving Party, the Designating Party may make the appropriate confidentiality designation at the time the copies are produced to the receiving party.

         5. The Parties shall use information designated as Confidential solely for purposes of these proceedings and not for any other purpose whatsoever, unless the Court permits such additional use or disclosure upon noticed motion served on all ...


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