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Everest Stables, Inc v. Julio Canani

February 2, 2011

EVEREST STABLES, INC., PLAINTIFF,
v.
JULIO CANANI, INDIVIDUALLY AND D/B/A/ TARMA CORPORATION, ROGER LICHT, ANTONIO CARLOS AVILA, AND GODOLPHIN RACING LLC DEFENDANTS.



STIPULATED PROTECTIVE ORDER REGARDING CONFIDENTIAL DOCUMENTS AND INFORMATION

WHEREAS, plaintiff Everest Stables, Inc. and defendants Julio Canani, individually and d/b/a Tarma Corporation, Roger Licht, Antonio Carlos Avila and Godolphin Racing LLC (individually each a "Party" and collectively the "Parties"), believe that good cause exists for entry of this Stipulated Protective Order (the "Protective Order"); and

WHEREAS, the Parties have, through counsel, stipulated to entry of this Protective Order pursuant to Fed. R. Civ. P. 26(c) to prevent unnecessary disclosure or dissemination of Confidential Information;

IT IS HEREBY ORDERED that the following provisions of this Protective Order shall govern Confidential Information produced by a Party or its affiliates in the course of this civil action:

1. "Confidential Information" shall mean information and tangible things that the designating Party reasonably and in good faith believes contain: a) non-public proprietary information of one of the Parties, their affiliates, or a third party; and b) non-public financial information that has not previously been disclosed to any person or entity absent a confidentiality agreement (including without limitation banking transactions); c) non-public information of a personal or intimate nature regarding an individual; or d) any other category of non-public information hereinafter given confidential status by mutual agreement of the Parties and/or by order of this Court. Confidential Information may be contained in discovery information or materials produced or obtained in this action by or through any means. All copies, recordings, abstracts, excerpts, analyses or other writings that contain, reveal or otherwise disclose such Confidential Information shall also be deemed to contain Confidential Information, as applicable. Information previously disclosed to the public shall not be deemed Confidential Information.

2. Confidential Information may be disclosed, disseminated and used by the receiving Party only for purposes of this civil action. Confidential Information shall not be disclosed except in accordance with the terms, conditions, and restrictions of this Protective Order, except with the prior written consent of the producing Party or upon prior order of this Court.

3. The term "producing Party" means the Party or person disclosing the information and designating it as Confidential Information under this Protective Order.

4. The term "receiving Party" means the Party to whom the Confidential Information is disclosed.

5. The Parties may designate material containing Confidential Information in the following manner:

a. Documents produced in discovery that contain Confidential Information shall be designated by stamping the word "CONFIDENTIAL" on the margin of such documents, or using another reasonable method agreed to in writing by the Parties.

b. A Party may, on the record of a deposition or by written notice to opposing counsel not later than thirty days after receipt of the deposition transcript, designate any portions of a deposition "CONFIDENTIAL" based on a good faith determination that any portions so designated contain Confidential Information. To the extent possible, any portions so designated shall be transcribed separately and marked by the court reporter as "CONFIDENTIAL."

c. Confidential Information contained in any affidavit, brief, memorandum or other paper filed with the Court in this action may be designated as Confidential Information by indicating on the face of such documents that one or more Parties consider them to contain Confidential Information, as applicable.

6. Such designated information shall thereafter be subject to this Protective Order, and use or disclosure of such information so designated shall be restricted as set forth herein.

7. Material designated "CONFIDENTIAL" and any summary, description or report containing such information designated as "CONFIDENTIAL," may be disclosed only to the following persons, without leave of this Court:

a. the Court, persons employed by the Court, and stenographers transcribing the testimony or argument at a hearing, trial or deposition in ...


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