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Plot USA, Inc. v. Hyakawa

United States District Court, D. Nevada

July 20, 2018

PLOT USA, Inc., a Domestic Limited Liability Company, Plaintiff,
v.
TAKESHI “SEAN” HYAKAWA an individual, and YUKARI HIDAKA, an individual, Defendants.

          CLARK HILL PLLC DEANNA L. FORBUSH, ESQ. BERT WUESTER JR., ESQ. COLLEEN E. MCCARTY, ESQ. Attorneys for Plaintiff PLOT USA.

          BAUMAN LOEWE WITT & MAXWELL, PLLC MICHAEL C. MILLS, ESQ. Attorneys for Defendant, Takeshi "Sean" Hyakawa.

          COHEN IP LAW GROUP, PC MICHAEL N. COHEN ESQ. LIAM M. MCNAMARA Attorneys for Defendant, Takeshi "Sean" Hyakawa.

          STIPULATED PROTECTIVE ORDER RE: PROTECTION OF CONFIDENTIAL MATERIALS

         WHEREAS, the parties to the above-captioned action contemplate engaging in discovery, which may include, among other things, taking depositions and producing documents;

         WHEREAS, these discovery proceedings may involve the production of certain information that the parties (the "Parties," each a "Party") believe to be confidential and sensitive commercial, financial or business information; and

         WHEREAS, certain of the Parties are engaged in proprietary activities and may be harmed if certain non-public personal, business or other sensitive confidential information or documents were disclosed publicly;

         IT IS HEREBY STIPULATED by and between Plaintiff Plot USA, Inc. (“Plaintiff”), by and through its counsel, Deanna L. Forbush, Esq., Bert Wuester, Jr., Esq. and Colleen E. McCarty, Esq. of the law firm of Clark Hill PLLC, and Defendant Takeshi “Sean” Hayakawa (“Defendant Hayakawa”), by and through his counsel Michael C. Mills, Esq. of the law firm of Bauman Loewe Witt & Maxwell, PLLC and Michael N. Cohen, Esq. of the Cohen IP Law Group, PC, as follows:

1. Any party to this action may designate as "Confidential" any documents (and copies thereof or other information furnished through agreement or discovery, and any such materials or information shall be deemed confidential and shall be delivered or given only to counsel for the other parties hereto. Said counsel shall keep such documents and information confidential to themselves and shall not further disseminate or disclose any such confidential documents or information, except as hereinafter provided. The provisions of this Protective Order Re: Confidential Materials (hereafter the "Order") shall be applicable to any abstracts, summaries or similar materials prepared from, or based upon, such confidential documents or information.
2. Documents and tangible things designated as "Confidential" shall be given a stamped or typewritten indication to that effect.
3. The disclosure of confidential documents or information may be made only to individual parties, to current and former employees, officers or directors of parties in this action, to inside or outside counsel, to persons employed by or associated with outside counsel, including any expert witness(es) and/or experts retained or specially employed in anticipation of litigation or preparation for trial, and to any employee or officer of an institutional party specifically designated to assist outside counsel in this litigation and/or preparation for trial.
4. Disclosure of confidential documents or information, whether by consent of counsel for the producing party or pursuant to further Order of this Court, may be made only to: persons actively involved in the preparation of trial, trial or settlement of this case, and may be used by the person to whom such disclosure is made only for those purposes, and not for any business, competitive, or other purpose.
5. All persons, besides counsel for the parties, to whom confidential documents or information is given, shown, made available, or communicated shall execute an agreement, in the form attached hereto as Exhibit "A" not to disclose or use the information except in accordance with the terms of this Order. It shall be the responsibility of counsel making such disclosure of confidential documents or information to secure, prior to making such disclosure, such an executed agreement from the person to whom disclosure is to be made, and to retain the original of such executed agreement pending further Order of this Court or final disposition of this action.
6. Nothing contained herein shall preclude any party to this action from utilizing confidential documents or information in taking depositions which include any confidential documents, or materials as part of the exhibits to said deposition, and any corresponding videotape, shall be prepared with a designation, on the first page of the transcript and/or videotape, that the deposition contains confidential materials, and all copies of such confidential materials shall be kept and disseminated by any party to this action only in accordance with the terms of this Order. If during the course of any deposition in this matter, counsel for any party asserts that a question propounded to the deponent is based upon or derived from confidential documents or information, or that the deponent's answer to a question should be treated as confidential, the transcript containing said inquiry and the answer, and any corresponding videotape, shall be sealed and subject to disclosure only under the terms and provisions of this Order.
7. No. person shall attend those portions of any deposition at which confidential documents are utilized as exhibits, or when the examination is based upon confidential documents or information, unless such person has been authorized to receive disclosure of confidential documents or information pursuant to Paragraph 3 and 4 hereof. Any witness at any such deposition shall be required to sign the acknowledgment and agreement attached hereto as Exhibit "A" and shall not be allowed to remove from the place of deposition, hearing or trial copies of any confidential documents. In the event any witness refuses to execute the acknowledgment and agreement, the examination may nevertheless continue, and confidential documents or information may be employed in connection therewith, but the witness shall be provided with a copy of this Order and shall he advised that he or she is subject to sanctions to be imposed by this Court for his or her refusal 8. Confidential documents or information may be filed with or presented to the Court, or may be included in, attached to, or discussed in briefs, memoranda or other papers filed with the Court, but, if so, they shall be filed in a sealed envelope bearing the caption of this case and the language, "This envelope, filed in this case by (name of party), is not to be opened nor the contents thereof revealed except ...

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