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Fidelity Brokerage Services LLC v. Nordstrom

United States District Court, E.D. California, Sacramento Division

March 24, 2017

FIDELITY BROKERAGE SERVICES LLC, Plaintiff,
v.
JOHN NORDSTROM; and INNOVATION WEALTH MANAGEMENT, Defendants.

          Nina Huerta (SBN 229070) Locke Lord LLP Jennifer A. Kenedy South Wacker Drive Chicago Attorneys for Plaintiff

          STIPULATED PROTECTIVE ORDER

          Hon. Judge John A. Mendez, Judge

         FIDELITY BROKERAGE SERVICES LLC

         Plaintiff Fidelity Brokerage Services LLC ("Fidelity") and Defendants John Nordstrom ("Nordstrom") and Innovation Wealth Management ("IWM") (collectively with Nordstrom, "Defendants") hereby stipulate and agree that documents produced in discovery, documents utilized as exhibits and testimony provided in this case will be handled as follows:

         1. Disclosure and Use of Confidential Material and Information

         A. All information, documents, exhibits, and other materials produced or utilized as exhibits by Fidelity, Defendants, or any other person or entity in the above-captioned case, or testimony given at a deposition or hearing in this case, that is designated by the producing or testifying party to be "Confidential, " "Produced Pursuant to Confidentiality Agreement, " or the like ("Confidential Material and Information") shall be governed by the provisions of this Agreement. Information derived from Confidential Material and Information shall also be governed by this Agreement, and be deemed to be Confidential Material and Information as well.

         B. All Confidential Material and Information shall be used solely for purposes of the prosecution or defense of the above-captioned case, including post-hearing motions and appeals.

         C. A receiving party may disclose Confidential Material and Information only to: (a) counsel of record for the parties and employees of such counsel; (b) Nordstrom and any other key employees of IWM, to the extent there are any; (c) any nonparty expert retained in writing to testify or provide opinions (to the extent necessary to perform the assigned task); (d) the court in the above-captioned Action and its staff; (e) the Panel in this arbitration; (f) court reporters, if any, who are permitted to transcribe tapes or make a transcript of proceedings; and, (g) directors, officers, and employees of Fidelity or IWM who have a need to access such Confidential Material and Information for the above-captioned case.

         D. If a receiving party wishes to file Confidential Material and Information with this Court (including but not limited to as exhibits to case pleadings), the party must seek leave to make such a filing under seal.

         E. The parties may apply to the Court, depending on the portion of this proceeding in which they are produced or used as exhibits or testimony, for relief from the designation of documents or information on reasonable notice for good cause shown, F. The inadvertent failure to designate material as "Confidential" or the like shall not be deemed a waiver of any claim of confidentiality as to such matter, and the same thereafter may be corrected by supplemental written notice. It shall not be deemed a violation of this Agreement to have disclosed information not designated as Confidential that is subsequently so designated if disclosure was made prior to such designation.

         2. Third-Party Requests

         A. If, pursuant to legal process (i.e., subpoena, panel or court order, etc.), a party receives a request to disclose Confidential Material and Information, the receiving party shall notify the producing party by overnight courier and fax or email that it has received legal process. The receiving party shall not disclose such Confidential Material and Information prior to the return date (thereby giving the producing party an opportunity to challenge such process).

         B. The parties stipulate that any document or information containing what a party in good faith believes contain trade secrets, personal employment, financial or investment information, financial information (including revenues, costs, expenditures, compensation and profits), or details of business relationships, the identity of customers and/or customer contact, financial or investment information may be designated as "Confidential". C. By entering into this Agreement, no party shall be deemed to have agreed with or to any "confidential'* designation.

         3. Return of Confidential ...


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