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JAH IP Holdings, LLC v. Mascio

United States District Court, D. Colorado

February 25, 2014

JAH IP HOLDINGS, LLC and JH INVESTMENTS, LLC, Plaintiffs,
v.
DAVID MASCIO, NARDI CAPITALE, LLC, DELLA PAROLA CAPITAL RESEARCH, LLC, and DELLA PAROLA HOLDLING COMPANY, LLC, Defendants.

STIPULATED PROTECTIVE ORDER

KRISTEN L. MIX, Magistrate Judge.

Upon stipulation of the parties for an order pursuant to Fed.R.Civ.P. 26(c) that trade secret or other confidential information be disclosed onlv in designated ways:

1. As used in this Stipulated Protective Order, these terms have the following meanings:

(a) "Attorneys" means counsel of record;
(b) "Confidential" documents are documents designated pursuant to paragraph 2;
(c) "Confidential - Attorneys' Eyes Only'' documents are the subset of Confidential documents designated pursuant to paragraph 5;
(d) "Outside Vendors" means messenger, copy, coding, and other clerical-services vendors not employed by a party or its Attorneys; and
(e) "Written Assurance" means an executed document in the form attached as Exhibit A.

2. If a party has a good faith belief that certain documents or other materials or information subject to disclosure pursuant to a discovery or other request are confidential and should not be disclosed other than in connection with this action pursuant to Fed. R. Civ. P.26(cl, the party shall designate the document or other materials as "Confidential."

3. All Confidential documents, along with the information contained in the documents, shall be used solely for the purpose of this action, and no person receiving such documents shall, directly or indirectly, use, transfer, disclose, or communicate in any way the documents or their contents to any person other than those specified in paragraph 4. Any other use is prohibited.

4. Access to anv Confidential document shall be limited to:

(a) the Court and its staff;
(b) Attorneys, their law firms, and their Outside Vendors;
(c) persons or entities shown on the face of the document to have created, ...

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