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Zinc Solutions, Inc. v. Progenex Dairy Bioactives, Inc.

United States District Court, Ninth Circuit

October 8, 2013

ZINC SOLUTIONS, INC., Plaintiff,
v.
PROGENEX DAIRY BIOACTIVES, INC., a Delaware corporation; VENTUREPHARMA, LLC, a Wyoming limited liability company, Defendants.

BECKY WALKER JAMES, Law Offices of Becky Walker James, Pacific Palisades, CA. Attorneys for Zinc Solutions, Inc.

KURT DREIBHOLZ, Morris Polich & Purdy, LLP, Los Angeles, CA. Attorneys for Progenex Dairy Bioactives, Inc, Attorneys for Venture Pharma, LLC

DISCOVERY MATTER [PROPOSED] ORDER GOVERNING THE DESIGNATION AND HANDLING OF CONFIDENTIAL MATERIALS

ARTHUR NAKAZATO, Magistrate Judge.

WHEREAS Plaintiff Zinc Solutions, Inc. ("Zinc") and Defendants Progenex Dairy Bioactives, Inc. ("PDB") and VenturePharma, LLC ("VenturePharma"), by and through their attorneys of record listed below agree on the following language of a proposed confidentiality order ("Confidentiality Order") in connection with prosecution of this fraudulent transfer action, including any and all discovery produced in connection therewith,

Accordingly, IT IS HEREBY STIPULATED AND AGREED by and between Zinc, PDB, VenturePharma, and their respective counsel, that the following definitions and procedures will govern the designation and handling of Confidential Material received by the Parties:

1. This Confidentiality Order shall apply to any information, document, thing or portion thereof, and any other form of evidence or discovery produced by a Party or a non-party (the "Confidential Materials") in this fraudulent transfer action.

2. This Confidentiality Order shall prohibit disclosure of any and all of the Confidential Materials to any person or entity except in accordance with the terms, conditions, and restrictions of this Confidentiality Order.

3. Subject to the terms, conditions, and restrictions of this Confidentiality Order, Confidential Materials shall not be disclosed by anyone to any person or entity except to PDB, VenturePharma, Zinc, and those persons that are directly involved with the prosecution and resolution of this fraudulent transfer action. No Confidential Materials shall be posted onto any internet site, nor published in any way, by any party or person.

4. In addition, Confidential Materials may be disclosed by counsel for Zinc, PDB, or VenturePharma to the following persons and entities in connection with counsel's efforts to pursue the prosecution and resolution of this fraudulent transfer action:

a. Employees, contractors, consultants of, or others engaged by, Zinc's counsel in connection with the prosecution and resolution of this fraudulent transfer action;
b. Employees, contractors, consultants of, or others engaged by, PDB and VenturePharma's counsel in connection with the prosecution and resolution of this fraudulent transfer action;
c. Court reporters and other persons involved in recording testimony in connection with the prosecution of this fraudulent transfer action;

d. This Court and/or other persons employed by the Court whose duties require access to any information filed in connection with the prosecution and resolution of this fraudulent transfer action.

5. Before Confidential Materials, or contents thereof, are disclosed to any person authorized to receive the same, counsel shall advise the recipient of the existence of this Confidentiality Order and said person must agree (a) to be bound by the terms hereof by signing the "Agreement to be Bound by the Confidentiality Order" attached hereto as Exhibit A, (b) to maintaining the received Confidential Materials in confidence, and (c) not to disclose ...


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