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Kevin Moats, An Individual; Kevin Moats & Associates, Inc., A Colorado v. Sunny Designs

March 16, 2012

KEVIN MOATS, AN INDIVIDUAL; KEVIN MOATS & ASSOCIATES, INC., A COLORADO CORPORATION; AND TRIANGLE INTERNATIONAL TRADING LTD, A BRITISH VIRGIN ISLANDS CORPORATION; PLAINTIFFS/COUNTER-DEFENDANTS;
v.
SUNNY DESIGNS, INC., A CALIFORNIA CORPORATION; AND DOES 1 THROUGH 10, INCLUSIVE; DEFENDANTS/COUNTER-PLAINTIFFS.



The opinion of the court was delivered by: Honorable Dale S. Fischer

Anthony Lanza, (Bar No. 156703) tony@lanzasmith.com Brodie H. Smith, (Bar No. 221877) brodie@lanzasmith.com LANZA & SMITH A Professional Law Corporation 3 Park Plaza, Suite 1650 Irvine, California 92614-8540 (949) 221-0490 Fax (949) 221-0027 Attorneys for Plaintiffs KAUFMAN DOLOWICH VOLUCK & GONZO LLP Wendell Hall SBN 185387 whall@kdvglaw.com Sylvia J. Hwang SBN 262440 shwang@kdvglaw.com 11755 Wilshire Boulevard, Suite 2400 Los Angeles, California 90025 Telephone: (310) 775-6511 Facsimile: (310) 525-9720 Attorneys for Defendant/Counter-Plaintiff, SUNNY DESIGNS, INC.

STIPULATED CONFIDENTIALITY PROTECTIVE ORDER

Complaint Filed: July 26, 2011 Trial Date: April 16, 2013

The parties stipulate and request that the Court enter the following protective order:

PROTECTIVE ORDER

Good cause appearing, IT IS HEREBY ORDERED as follows:

1. Purpose

The purpose of this Stipulation and Protective Order is to allow the Parties to have reasonable access to information from others while protecting proprietary or confidential information from public disclosure without frequent resort to determinations of discoverability by the Court.

2. Definitions

2.1. "Person" means any natural person, corporation, partnership, proprietorship, group, association, organization, business entity, governmental body, agency, and any agent of the foregoing.

2.2. "Party" or "Parties" means any of the parties in this action, including officers, directors, and managing employees of such parties.

2.3. "Document" has the same meaning as in the operative Federal Rules of Civil Procedure and/or California Code of Civil Procedure, as the case may be (the "Discovery Act").

2.4. "Discovery Material" means any information or Document produced in response to or in anticipation of any discovery under the Discovery Act, including deposition testimony.

2.5. "Disclose" or "Disclosure" means to show, give, make available, or communicate, in any fashion, to any Person, any Discovery Material or information concerning the contents or substance of any Discovery Material.

2.6. "Producing Person" means any Person, whether a party or a non-party, that Discloses any Discovery Material.

2.7. "Designating Person" shall mean a Person who designates Discovery Material as confidential, limited to (a) a Producing Person, or (b) a Person asserting a proprietary interest in the information who has a lawful right to restrict the Disclosure of the information.

2.8. "Confidential Information" means any Discovery Material that any Designating Person designates as confidential, subject to any party's right to challenge such designation through Court intervention, as specified herein.

2.9. "Receiving Party" means a party to this action that receives ...


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