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Custom Hair Designs by Sandy, LLC v. Central Payment Co., LLC

United States District Court, D. Nebraska

January 23, 2018

CUSTOM HAIR DESIGNS BY SANDY, LLC, and SKIP'S PRECISION WELDING, LLC, on behalf of themselves and all others similarly situated, Plaintiffs,
v.
CENTRAL PAYMENT CO., LLC, Defendant.

          Tyler W. Hudson, Eric D. Barton, Grand Avenue Counsel for Plaintiffs

          Kenneth W. Hartman, David L. Balser (pro hac vice), Jonathan R. Chally (pro hac vice), Brandon R. Keel (pro hac vice) Allison Hill White (pro hac vice) Counsel for Defendant

          JOINT STIPULATION AND PROPOSED PROTECTIVE ORDER GOVERNING CONFIDENTIAL INFORMATION

         In order to protect the confidentiality of certain discovery materials produced in the above-captioned case (the “Action”), the parties to the Action hereby stipulate and agree to the terms and conditions set forth below:

         1. This Protective Order shall govern all information, data, documents, and other materials produced or received by any party through discovery in the Action, including, but not limited to, information obtained through responses to interrogatories, responses to requests for production, responses to requests for admission, deposition testimony, or a subpoena issued from the Court (collectively, “Discovery Material”).

         2. Discovery Material designated as “Confidential” or “Highly Confidential” shall be used solely for the purposes of this Action and in accordance with the terms of this Protective Order.

         3. Discovery Material may be designated as “Confidential” or “Highly Confidential” (together, “Confidential Material”) by (1) imprinting the word “Confidential” or the words “Highly Confidential” on any Discovery Material; or (2) notifying the other party in writing, or on the record in a deposition, or in Court that any Discovery Material should be treated as Confidential or Highly Confidential. Deposition transcripts shall be presumptively treated as Confidential Material for fifteen (15) days following the parties' receipt of the transcripts, to allow time for the parties to designate the transcripts, or portions thereof, as Confidential or Highly Confidential in accordance with this Protective Order.

         4. A party may designate Discovery Material as Confidential if the party has a good faith belief that the material is not in the public domain and that it contains proprietary, trade secret, or other commercially or competitively sensitive information, or any information involving a person's privacy interest. A party may designate Discovery Material as Highly Confidential if the party makes a good faith determination that the material contains proprietary, trade secret, or other highly sensitive business information that, if revealed, could place the designating party at a competitive or commercial disadvantage, or that disclosure would contravene an obligation of confidentiality. Notwithstanding the above, the following Discovery Material shall not be deemed Confidential or Highly Confidential regardless of any such designation by a party:

i. Information, materials, or documents already in a receiving party's possession that were not acquired or obtained through discovery in the Action;
ii. Information, materials, or documents that are generally available to the public, including information which becomes available to the public through no breach of this Agreement.

         5. Any copies or reproductions, summaries, or other documents or materials that excerpt, contain, or otherwise reveal the substance of Confidential Material also shall be treated as Confidential Material pursuant to this Protective Order.

         6. The inadvertent or unintentional failure to designate Confidential Material as such shall not be deemed a waiver in whole or in part of a party's claim of confidentiality, either as to the specific document or information disclosed or as to any other document, material, or information relating thereto. Any such inadvertently or unintentionally disclosed Confidential Material shall be designated as Confidential or Highly Confidential within a reasonable time after the designating party becomes aware of the erroneous disclosure and shall thereafter be treated as Confidential Material by all receiving persons. Upon receipt of the designated Confidential Material, the receiving party shall destroy or return all printed and electronic copies of such material that were inadvertently not designated as Confidential or Highly Confidential as soon as reasonably practical but in no event more than five (5) business days after receipt of the designated Confidential Material.

         7. Without the consent of the designating party, Discovery Material designated as Confidential shall not be disclosed directly or indirectly by the receiving party to persons other than:

(a) The parties;
(b) Counsel of record for the parties, including counsels' employees and vendors who need to review the Confidential ...

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