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Securities and Exchange Commision v. Thomas

United States District Court, D. Nevada

October 28, 2019

SECURITIES AND EXCHANGE COMMISSION, Plaintiff,
v.
JOHNNY R. THOMAS, ROBERT C. POTTS, JONATHAN BRETT WOODARD, and JOHN C. FRANCIS, Defendants.

          Suzanne J. Romajas Securities and Exchange Commission Attorney for Plaintiff

          Randall R. Lee Jessica Valenzuela Santamaria Amy M. Smith Cooley LLP Adam C. Trigg Bergeson LLP Attorneys for Defendants Thomas and Francis

          Jonathan D Bletzacker Brent R. Baker Clyde Snow & Sessions Attorneys for Defendants Potts and Woodard

          STIPULATION AND [PROPOSED] PROTECTIVE ORDER WITH RESPECT TO THE PRODUCTION OF SENSITIVE PERSONAL INFORMATION AND [PROPOSED] NON-WAIVER AND CLAWBACK ORDER

         WHEREAS, the parties are engaged in disclosure and discovery activity in this matter that will include, among other things, the initial service of documents identified in the parties' Rule 26(a) reports, the production of documents and information by parties and non-parties in response to subpoenas and other requests for information, and the taking of testimony;

         WHEREAS, portions of many such documents, information, and transcripts will likely contain personally identifiable information about individuals, including the Defendants in this matter; and

         WHEREAS, the parties desire to protect such information from use for any purpose other than this litigation and therefore desire to expand the protections offered by Federal Rule of Civil Procedure 5.2(a) and Local Rule IC 6-1 of the United Stated District Court for the District of Nevada;

         ACCORDINGLY, Plaintiff Securities and Exchange Commission, and Defendants Johnny R. Thomas, Robert C. Potts, Jonathan “Brett” Woodard, and John C. Francis, through their respective counsel, hereby stipulate to and petition the Court to enter the following Stipulated Protective Order:

         As used in this Order, the term “Sensitive Personal Information” shall include any one or more of the following categories of personal and private information: (a) a social security or tax identification number; (b) individuals' financial information, including but not limited to statements or account numbers for any bank account, credit card account, brokerage account, fund transfer or payment facilitation account, mortgage, or loan; (c) biometric data, such as a finger or voice print; (d) tax information, including but not limited to tax returns; (e) the phone number(s) of any individual person; (f) the birth date of any individual person; (g) the name of any individual person who, at the time of the filing of the Complaint in this action, was known to be less than 18 years old; (h) medical information, and/or (i) the maiden name of an individual's mother.

         Sensitive Personal Information does not include public information about an individual that is lawfully available to the general public.

         Sensitive Personal Information produced during the course of this litigation shall not be used by any party to this litigation (“Party”) except as expressly permitted hereunder.

         Sensitive Personal Information:

         1. Shall be used by the Parties for the purposes of this litigation only; 2. Shall not be used by the Parties for any business or commercial purposes; 3. Shall not be disclosed to any third party, published or otherwise made public in any form by any Party except as permitted below; 4. May be disclosed only to the following persons, on an as-needed basis in the course of the litigation:

a. A Party;
b. Counsel for any Party and employees and agents of counsel who have responsibility for the preparation and trial of this action, including but not limited to attorneys, employee consultants, legal support staff, and any person or entity ...

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