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Dunlap v. Amato

United States District Court, D. Nevada

November 15, 2019

JOSEPH TODD DUNLAP, an individual, MONA DUNLAP, an individual, Plaintiffs,
v.
DOMINIC AMATO, an individual, WHITE RIVER MARINE GROUP, a Missouri business entity, TRACKER MARINE GROUP, a Missouri business entity, TRACKER MARINE LLC, a Missouri limited liability company, TRACKER MARINE RETAIL, LLC, a Delaware limited liability company, DOES 1 through X, inclusive, and ROE CORPORATIONS 1 through X, inclusive, and ROE LIMITED LIABILITY COMPANIES 1 through X, inclusive, Defendants. DOMINIC AMATO, Cross-Complainant, WHITE RIVER MARINE GROUP, TRACKER MARINE GROUP, TRACKER MARINE, LLC, AND TRACKER MARINE RETAIL, LLC, Cross-Defendants.

          K&L GATES LLP Christina Paul, Esq.

          GIBSON ROBB & LINDH LLP Chelsea Yuan, Esq. Attorneys for Defendant Dominic Amato

          STONER GRANNIS LLP William Stoner William Stoner, Esq. Attorneys for Plaintiffs

          JOINT STIPULATED AGREEMENT GOVERNING THE PROTECTION AND USE OF CONFIDENTIAL INFORMATION

         The parties enter this Joint Stipulated Agreement Governing the Protection and Use of Confidential Information (the “Agreement”) to preserve the confidentiality of certain materials. The parties hereby stipulate that a Protective Order may be entered by this Court as follows:

         1. All documents and information produced by the parties in this action shall be used by any party receiving them solely for the purposes of preparing for and conducting the above-captioned litigation, including any appeals therefrom, and not for any other purpose whatsoever.

         2. The term “Confidential, ” for purposes of this Agreement, shall mean any information, document or thing so designated by any party to this litigation or any third party producing information, documents or things in this litigation, including (without limitation) documents, information contained in documents or other media (including any form of optical or magnetic storage media), and information revealed during a deposition, in response to a subpoena, or in an interrogatory answer or an admission. The designation of “Confidential” may be placed on documents and information which are a trade secret, confidential business information, proprietary information, and/or personal information. The term “documents” shall include any hard copy documents or electronically stored information-including writings, drawings, graphs, charts, photographs, sound recordings, images, electronic mail (“e-mail”), text messages, and other data or data compilations-stored in any medium from which information can be obtained either directly or, if necessary, after translation by the responding party into a reasonably usable form.

         3. The Designations shall be as follows:

(a) Written information or documents, or any portion thereof, shall be designated as “Confidential” by placing on each page a stamp or notice stating “CONFIDENTIAL” in a manner that will not interfere with the legibility of the written information.
(b) Interrogatory responses containing “Confidential” information shall be set forth on separate pages from interrogatory responses which do not contain such information and all pages of interrogatory responses containing “Confidential” shall be produced in a separate package from interrogatory responses which do not contain such information.
(c) Documents produced, filed, or served by a party and designated “Confidential” shall be so marked by such party prior to or at the time they are produced, filed, or served. Documents produced by a third party as to which a “Confidential” designation is claimed by any person shall be so designated within ten days after they are produced, and shall be treated as “Confidential” during the intervening time.

         4. Information disclosed at a deposition may be designated as “Confidential” by a statement on the record that the testimony, or part of the testimony, is “Confidential” and subject to the provisions of this Agreement. In addition, the transcript of such a deposition and all information exchanged in such a deposition shall be considered “Confidential” for a period of ten days after receipt of the deposition transcript. During those ten days, any party may designate any additional portion or the entire transcript as “Confidential” and all other persons given notice of the designation shall treat the information accordingly.

         5. Use of the confidential information shall be as follows:

(a) Documents and/or information designated as “Confidential” shall be used only for purposes of this litigation and shall not be disclosed, given, shown, made available or communicated in any way to anyone other than the following:
(i) Attorneys representing a Party to the action, and the employees of such attorneys or their law firms, but only for the ...

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