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ACI Worldwide Corp. v. Churchill Lane Associates, LLC

United States District Court, District of Nebraska

October 9, 2014

ACI WORLDWIDE CORP., Plaintiff,
v.
CHURCHILL LANE ASSOCIATES, LLC, Defendant.

STIPULATED PROTECTIVE ORDER

F.A. Gossett United States Magistrate Judge

Upon the agreement of the parties (filing 7), a Stipulated Protective Order (“Order”) is entered as follows:

1. This Order shall apply to and govern all depositions, documents, information or things disclosed or produced in response to a party’s informal request, requests for production of documents, answers to interrogatories, responses to requests for admissions and all other discovery taken under the Federal Rules of Civil Procedure, and other information which the disclosing party designates as “CONFIDENTIAL, ” furnished, directly or indirectly, by or on behalf of any party or any non-party in connection with the above-captioned litigation.

2. When used in this Order, the phrase “disclosing party” shall refer to the parties to the above-captioned litigation or to non-parties who give testimony or produce documents or other material.

3. When used in this Order, the word “document” encompasses, but is not limited to, any type of document or testimony, including all documents or things described in Federal Rule of Evidence 1001(a)-(e) and/or Rule 34(a)(1)(A) or (B).

4. The disclosing party who designates any material “CONFIDENTIAL” (sometimes referred to herein as a “designating party”) bears the burden of establishing the “CONFIDENTIAL” status of such material in any situation in which the designation is at issue, and nothing in this Order shall be construed to alter such burden. The parties enter into and stipulate to this Order without prejudice to the rights of any party to assert or contest the “CONFIDENTIAL” status of any material as set forth below.

5. A disclosing party may designate as “CONFIDENTIAL” any trade secret or other confidential research, development, or commercial information, as such terms are used in Rule 26(c)(1)(G) and any applicable case law interpreting Rule 26(c)(1)(G). In addition, a disclosing party may designate as “CONFIDENTIAL” non-public personal information or other information for which applicable federal or state law requires or allows confidential treatment.

6. In designating material as “CONFIDENTIAL, ” a disclosing party shall make such a designation only as to material which it in good faith believes is confidential.

7. Any party or non-party receiving any non-public material from a disclosing party, regardless of whether such material is designated as “CONFIDENTIAL, ” shall use that material solely for the purpose of conducting this litigation, pending in the United States District Court for the District of Nebraska, captioned ACI Worldwide Corp. v. Churchill Lane Associates, LLC, Case No. CI 14-0249, and not for any other purpose whatsoever.

8. In the absence of written permission from the disclosing party, or an order of the Court, material designated as “CONFIDENTIAL” may be disclosed only to the following persons:

(a) The named parties, including designated company representatives Alan Wiener, Dr. Robert Carroll and Alvin Siteman for Defendant and Dennis Byrnes for Plaintiff, all of which shall sign the “ACKNOWLEDGMENT” attached hereto as Exhibit “A, ” and the attorneys working on the above-captioned litigation on behalf of any party, including attorneys consulting with or advising any party to the above-captioned litigation, in-house attorneys, paralegals, and staff, stenographic and clerical employees and contractors working under the direct supervision of such counsel;
(b) Any expert or consultant who is expressly retained by any attorney described in Paragraph 8(a) to assist in the above-captioned litigation, with disclosure only to the extent reasonably necessary to perform such work, which expert or consultant shall sign the “ACKNOWLEDGMENT” attached hereto as Exhibit “A”;
(c) Any fact witness, including named parties, provided, however, that the witness (i) shall be permitted to use any documents marked as “CONFIDENTIAL” only in preparation for and during depositions, hearings and trial, (ii) shall be informed, prior to being shown materials marked as “CONFIDENTIAL” that he/she is being shown such materials solely for use in this litigation and (iii) shall sign the “ACKNOWLEDGMENT” attached hereto as Exhibit “A”;
(d) Any individual who either prepared the document or is identified on the face of the document as an ...

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