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Fryberger v. Triptelevision, LLC

United States District Court, D. Colorado

December 18, 2015

CHARLES F. FRYBERGER d/b/a CHUCK FRYBERGER FILMS, Plaintiff,
v.
TRIPTELEVISION, LLC, a Nevada company, KULIN STRIMBU, an individual, ELIZABETH HOLT, an individual, RICH MEDIA EXCHANGE, LLC, a Colorado company APPLE VACATIONS, LLC, a Delaware Corporation, Defendants.

Scott E. Brenner Thomas P. Howard William C. Groh Thomas P. Howard, LLC Attorneys for Plaintiff Chuck Fryberger

Joy Allen Woller Frederick J. Baumann LEWIS ROCA ROTHGERBER LLP Attorneys for Defendant Apple Vacations, LLC

PROPOSED PROTECTIVE ORDER

NINA Y. WANG UNITED STATES MAGISTRATE JUDGE.

The following provisions are necessary for the protection of the parties confidential, proprietary, or otherwise protected information pursuant to the provisions F.R.CP. 26(c).

IT IS HEREBY ORDERED THAT:

1. AUTHORIZED DESIGNATION UNDER PROTECTIVE ORDER AND NON-WAIVER

A. Each party producing information including, but not limited to, any document, record, electroncially stored information (“ESI”) or tangible thing (collectively “Documents”) in this litigation shall label it as “Confidential” to the extent that the providing party believes in good faith that the information falls within the scope of protection defined more fully in Paragraph 2 below, and as “Attorneys’ Eyes Only” to the extent that the providing party believes in good faith that the information falls within the scope of protection defined more fully in Paragraph 3 below. ESI that is converted to an image format (PDF or TIFF) for production shall be designated by affixing the appropriate designation to the image. ESI produced in a non-image format shall be designated by including the appropriate designation in the file name of the produced file and/or also by producing a slip sheet bearing the bates number (if any), file name, and the appropriate designation.

B. Non-waiver.

1) The failure to designate materials as “Confidential” or “Attorneys’ Eyes Only” at the time of production shall not preclude the producing party from imposing such designation at a later time if it believes in good faith that the information falls within the scope of protection defined more fully in Paragraph 3 below. If a producing party fails to designate a Document as “Confidential” or “Attorneys Eyes Only” in the first instance and later discovers that the Document should have been so designated, it shall may do so by promptly notifying the receiving party or parties and providing a replacement copy of the Document bearing the new Designation.
2) If a receiving party objects to the new designation, it shall follow the challenge procedure outlined in Paragraph 7 below.
3) If the receiving party used the document in a manner inconsistent with the new designation prior to receiving such notice, then such prior use is not a breach of this Order. However, upon receipt of such notice and until the resolution of any dispute concerning such designation, the receiving party shall treat the document in accordance with the new designation provided.

2. ITEMS THAT QUALIFY FOR “CONFIDENTIAL” DESIGNATION

A party may designate as “Confidential” any business documents, correspondence, testimony, or other sensitive or private information that the disclosing party believes should remain confidential between the parties to the lawsuit and not be disclosed to any third party.

3. ITEMS THAT QUALIFY FOR “ATTORNEYS’ EYES ONLY” DESIGNATION

A party may designate as “Attorneys’ Eyes Only” any document, tangible thing, testimony, or other data related to: any proprietary, sensitive business or technical information that would provide a significant advantage to the party’s competitors if disclosed, including for example, business development plans, trade secrets, proprietary information, competitor market analyses, customer lists, bidding ...


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