Johnson et al v. INTU Corporation, No. 2:2018cv02361 - Document 95 (D. Nev. 2020)
Court Description: PROTECTIVE ORDER GRANTING ECF No. 94 Proposed Stipulated Protective Order. Signed by Magistrate Judge Nancy J. Koppe on 5/7/2020. (Copies have been distributed pursuant to the NEF - DRM)
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Johnson et al v. INTU Corporation Doc. 95 Case 2:18-cv-02361-MMD-NJK Document 95 Filed 05/07/20 Page 1 of 14 1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 DISTRICT OF NEVADA 10 KRYSTAL JOHNSON, on behalf of herself Case Number: 2:18-cv-02361-MMD-NJK 11 and all others similarly situated, an individual: ELIZABETH SPANGLER, on 12 behalf of herself and all others similarly situated, an individual, 13 ORDER GRANTING Plaintiffs, PROPOSED STIPULATED 14 PROTECTIVE ORDER vs. 15 INTU, a Nevada corporation; DEANNA 16 EDWARDS, an individual, 17 Defendants. 18 19 Plaintiffs Krystal Johnson and Elizabeth Spangler (together, “Plaintiffs”), by and through 20 their attorneys of record, The VerStandig Law Firm, LLC, and Defendants INTU Corporation and 21 Deanna Edwards (together, “Defendants”), by and through their attorneys of record, the law firm 22 of Marquis Aurbach Coffing, hereby enter into this Stipulated Protective Order (“Order”) pursuant 23 to the provisions of Federal Rules of Civil Procedure (“FRCP”) 26(c). Plaintiffs and Defendants 24 may each be referred to herein, individually, as a “Party” or, collectively, as the “Parties.” 25 The Parties have agreed and stipulated to the entry of this Order for the protection of 26 confidential and sensitive documents, records, and information produced or otherwise disclosed by 27 the Parties in this action. Page 1 of 14 MAC:16072-001 4039816_1 5/6/2020 1:07 PM Dockets.Justia.com Case 2:18-cv-02361-MMD-NJK Document 95 Filed 05/07/20 Page 2 of 14 1 IT IS HEREBY STIPULATED AND AGREED, by and between the Parties, through their 2 respective counsel of record, that the following terms and conditions shall govern the disclosure, 3 production, and use of documents and information in this action: 4 I. DEFINITIONS 5 1. “Material” refers to any document, data compilation, testimony, report, 6 interrogatory response, response to a request for admission, response to a request for production, or 7 other information in any form produced or disclosed in this action (including copies), whether 8 voluntarily or through any means of discovery authorized by law, and whether by a Party or non9 party. 2. Material may be designated “Confidential” if the Designating Party in good faith 11 believes that disclosure of such Material in this action without the designation presents a risk of 10001 Park Run Drive Las Vegas, Nevada 89145 (702) 382-0711 FAX: (702) 382-5816 MARQUIS AURBACH COFFING 10 12 injury to the legitimate business or personal interests of the Disclosing Party, or any other 13 legitimate interest of the Disclosing Party. Confidential information includes, but is not limited to, 14 all Materials reflecting, referring to, or evidencing any information deemed confidential by any 15 local, state, or federal statute, ordinance, regulation, or other law, confidentiality agreement, 16 business plans or forecasts, financial plans and forecasts, operational plans and forecasts, and all 17 private or sensitive commercial, technical, financial, proprietary, personal, personnel, underwriting, 18 rating, claims and insurance policy information, which is not publicly known and cannot be 19 ascertained from an inspection of publicly-available documents or materials. Confidential 20 information may take the form of, but is not limited to, (a) documents, responses to request for 21 production, interrogatory responses, or responses to requests for admissions; (b) hearing or 22 deposition transcripts and related exhibits; and, (c) all copies, abstracts, excerpts, analyses, reports, 23 and complete or partial summaries prepared from or containing, reflecting, or disclosing such 24 confidential information. 25 3. Material may also be designated as “Sensitive-Attorney Eyes Only.” Sensitive- 26 Attorney Eyes Only Material must meet the Confidential designation requirements of Section I(2) 27 and must be so proprietary or competitively sensitive or contain such highly sensitive and nonPage 2 of 14 MAC:16072-001 4039816_1 5/6/2020 1:07 PM Case 2:18-cv-02361-MMD-NJK Document 95 Filed 05/07/20 Page 3 of 14 1 public business, technical, financial, personal, or other information that its disclosure to persons 2 other than those enumerated in Section IV will irreparably harm the Disclosing Party. 3 4. “Disclosing Party” refers to a Party, or non-party, to this action who produces 4 Material. 5 5. “Designating Party” refers to a Party or non-party to this action who designates 6 Material as Confidential or Sensitive-Attorney Eyes Only. 7 6. “Requesting Party” refers to a Party who has made a discovery request. 8 7. “Receiving Party” refers to a Party who receives, or is otherwise exposed to, 10001 Park Run Drive Las Vegas, Nevada 89145 (702) 382-0711 FAX: (702) 382-5816 MARQUIS AURBACH COFFING 9 Material during the course of this action. 10 II. SCOPE OF PROTECTIVE ORDER 11 1. Except as the Parties may otherwise agree, or the Court may order, any Material 12 produced in this action, which is designated Confidential or Sensitive-Attorney Eyes Only, 13 including any report, excerpt, analysis, summary, or description of it, shall be strictly controlled by 14 this Order, and no disclosure or use of such Material, by any Receiving Party, can be made except 15 in accordance with the requirements of this Order. All Material designated Confidential or 16 Sensitive-Attorney Eyes Only shall be used solely for the prosecution or defense of this action. 17 2. This Order shall govern all Material produced in this action, including Material 18 produced prior to entry of this Order. 19 3. The protections of this Order shall not apply to Material that, prior to disclosure in 20 this action, was within the actual possession or knowledge of a Receiving Party but was not subject 21 to any confidentiality obligation between the Parties, was previously disclosed by a Disclosing 22 Party to a non-party to this action without any obligation of confidentiality, or was actually public 23 knowledge, provided that the Material did not become public knowledge through an act or 24 omission of a Receiving Party. Material that was in the hands of the Receiving Party prior to 25 disclosure in this action, however, and was subject to a confidentiality obligation between the 26 Parties, shall be made subject to this Order. Any Party who claims that the Material was, prior to 27 Page 3 of 14 MAC:16072-001 4039816_1 5/6/2020 1:07 PM Case 2:18-cv-02361-MMD-NJK Document 95 Filed 05/07/20 Page 4 of 14 1 disclosure in this action, within its actual possession or knowledge and was not subject to a 2 confidentiality obligation or was public knowledge shall have the burden of proving that fact. 3 4. Nothing in this Protective Order shall be construed to prohibit counsel from 4 providing advice, guidance, or counsel to a Party, regardless of whether such advice, guidance, or 5 counsel is based, in whole or in part, upon information counsel learned from Material designated 6 Confidential or Sensitive-Attorney Eyes Only, so long as counsel does not disclose Confidential or 7 Sensitive-Attorney Eyes Only Material to anyone not permitted to receive such Material under this 8 Order. 10001 Park Run Drive Las Vegas, Nevada 89145 (702) 382-0711 FAX: (702) 382-5816 MARQUIS AURBACH COFFING 9 III. DESIGNATION OF MATERIAL 10 A. GENERAL PROVISIONS 11 1. A Designating Party may designate Material as Confidential or Sensitive-Attorney 12 Eyes Only, only if the Material (1) is Confidential, as defined by Section I(2), or Sensitive13 Attorney Eyes Only, as defined by Section I(3); and, (2) is not excluded from the scope of this 14 Order by Section II(3). 15 2. A Designating Party’s failure to designate Material as Confidential or Sensitive- 16 Attorney Eyes Only at the time of production or disclosure of the Material does not waive its right 17 to later designate the Material as Confidential or Sensitive-Attorney Eyes Only, so long as the 18 Designating Party notifies all Parties in writing of the failure within a reasonable time period after 19 learning that the Material was produced without an appropriate confidentiality designation. After 20 any designation, each Receiving Party shall treat the designated Material as either Confidential or 21 Sensitive-Attorney Eyes Only and subject to the protections of this Order. 22 B. METHODS OF DESIGNATION 23 1. A Designating Party may designate Material as Confidential by placing or affixing 24 on the Material the word “Confidential.” 25 2. A Designating Party may designate Material as Sensitive-Attorney Eyes Only by 26 placing or affixing on the Material the words “Sensitive-Attorney Eyes Only.” 27 / / / Page 4 of 14 MAC:16072-001 4039816_1 5/6/2020 1:07 PM Case 2:18-cv-02361-MMD-NJK Document 95 Filed 05/07/20 Page 5 of 14 1 3. Testimony, including hearing or deposition transcripts, or portions of such 2 transcripts, and any applicable exhibits, may be designated Confidential or Sensitive-Attorney 3 Eyes Only by: (a) counsel so stating on the record during the hearing or deposition, or (b) 4 providing written notice to the reporter and all counsel of record. All transcripts of hearings or 5 depositions, or portions of such transcripts, and any applicable exhibits, shall be considered as 6 designated Confidential, except for any testimony or exhibits designated as Sensitive-Attorney 7 Eyes Only at the time of the hearing or deposition, until 30 days after the reporter sends notice that 8 the written transcript is available for review. The Parties may, however, designate transcripts, or 9 portions of such transcripts, and any applicable exhibits, as Confidential or Sensitive-Attorney 11 such a designation is made after the 30 day period, all designated Material shall be handled as 10001 Park Run Drive Las Vegas, Nevada 89145 (702) 382-0711 FAX: (702) 382-5816 MARQUIS AURBACH COFFING 10 Eyes Only at any time, including after the 30 day period described in the preceding sentence. If 12 Confidential or Sensitive-Attorney Eyes Only, depending on the asserted designation, from the 13 time of the designation forward and all Receiving Parties shall make reasonable efforts to recover 14 any transcripts or portions of transcripts that have been disclosed beyond what is allowed for the 15 asserted designation. If transcripts or portions of such transcripts, and any applicable exhibits are 16 designated as Confidential or Sensitive-Attorney Eyes Only, the Parties’ counsel and the court 17 reporter shall make reasonable arrangements to maintain the confidentiality of any deposition 18 testimony or exhibits so designated, in accordance with the terms of this Order. These 19 arrangements may include the marking of transcript pages, covers or exhibits, and other measures 20 to preclude the disclosure of Confidential or Sensitive-Attorneys Eyes Only Material other than to 21 qualified persons. 22 4. When Confidential or Sensitive-Attorney Eyes Only Material is supplied or stored 23 on a digital, electronic, or electromagnetic medium, the Confidential or Sensitive-Attorney Eyes 24 Only designation shall be made, to the extent physically possible, on the medium itself (such as on 25 a label attached to a disk), on the sleeve, envelope, box, or other container of such medium, or by 26 submitting a written statement to all counsel of record identifying the appropriate designation. 27 / / / Page 5 of 14 MAC:16072-001 4039816_1 5/6/2020 1:07 PM Case 2:18-cv-02361-MMD-NJK Document 95 Filed 05/07/20 Page 6 of 14 1 C. CHALLENGING CONFIDENTIALITY DESIGNATIONS 2 1. Any Party may challenge the designation of any Confidential or Sensitive-Attorney 3 Eyes Only information through court intervention. The Party making such a challenge shall give 4 the Designating Party written notice specifically setting forth the grounds for the objection to the 5 designation, not less than 14 judicial days before filing any motion challenging any designation. 6 During the above-identified notice period, the objecting Party shall meet and confer with the 7 Designating Party in good faith in order to resolve the dispute without filing a motion. If the good 8 faith meet-and-confer process fails, the objecting Party may then challenge the designation through 9 motion practice. 2. Notwithstanding any such challenge, all such Material shall be treated as 11 Confidential or Sensitive-Attorney Eyes Only as designated until one of the following occurs: (a) 10001 Park Run Drive Las Vegas, Nevada 89145 (702) 382-0711 FAX: (702) 382-5816 MARQUIS AURBACH COFFING 10 12 the Disclosing Party withdraws such Confidential or Sensitive-Attorney Eyes Only designation in 13 writing, or (b) the Court rules that the designation is not proper and that the designation shall be 14 removed. 15 IV. 16 DISCLOSURE, USE, AND HANDLING OF CONFIDENTIAL OR SENSITIVEATTORNEY EYES ONLY MATERIAL A. USE AND HANDLING OF CONFIDENTIAL OR SENSITIVE-ATTORNEY EYES ONLY MATERIAL 1. the issued extent concurrently any Materialherewith. filed with the Court, including pleadings, exhibits, SeeToorder 17 18 19 transcripts of hearings or depositions, expert reports, answers to interrogatories, and responses to 20 requests for admissions, contains or reveals Confidential or Sensitive-Attorney Eyes Only 21 Material, the Material or any portion thereof shall be filed under seal pursuant to the applicable 22 rules. 23 2. All copies, duplicates, extracts, summaries, reports, or descriptions (collectively 24 “copies”) of Materials designated as Confidential or Sensitive-Attorney Eyes Only, or any portion 25 thereof, shall immediately be affixed with the label Confidential or Sensitive-Attorney Eyes Only 26 if such label does not already appear thereon. 27 / / / Page 6 of 14 MAC:16072-001 4039816_1 5/6/2020 1:07 PM Case 2:18-cv-02361-MMD-NJK Document 95 Filed 05/07/20 Page 7 of 14 1 3. Material designated Confidential or Sensitive-Attorney Eyes Only does not lose 2 protected status through an unauthorized disclosure, whether intentional or inadvertent, by a 3 Receiving Party. If such a disclosure occurs, the Parties shall take all steps reasonably required to 4 assure the continued confidentiality of the Material. 5 4. Any Material that is designated Confidential shall not be disclosed to any person or 6 entity other than the following, and only after such person or entity has been advised of and has 8 (a) The Parties and their counsel of record; 9 (b) Counsel of record for the Parties; 10 (c) Members of the legal, paralegal, secretarial, or clerical staff of such counsel who are 11 assisting in or responsible for working on this action; 10001 Park Run Drive Las Vegas, Nevada 89145 (702) 382-0711 FAX: (702) 382-5816 MARQUIS AURBACH COFFING 7 agreed to be subject to the terms of this Order: 12 (d) The Court, its staff, the jury, and all appropriate courts of appellate jurisdiction and 13 their staff; 14 (e) Independent experts or consultants retained by a Party or counsels of record for 15 purposes of this litigation, and any employees, associates, or independent contractors retained by 16 those experts or consultants in their work in this litigation; 17 (f) Court reporters during depositions or hearings; 18 (g) Deponents during depositions or witnesses during hearings; 19 (h) Persons who have had, or whom any counsel for any party in good faith believes to 20 have had, prior access to the Confidential Material being disclosed, or who have been participants 21 in a communication that is the subject of the Confidential Material and from whom verification of 22 or other information about that access or participation is sought, solely to the extent of disclosing 23 such information to which they have or may have had access or that is the subject of the 24 communication in which they have or may have participated, except that, unless and until counsel 25 confirms that any such persons have had access or were participants, only as much of the 26 information may be disclosed as may be necessary to confirm the person’s access or participation; 27 / / / Page 7 of 14 MAC:16072-001 4039816_1 5/6/2020 1:07 PM Case 2:18-cv-02361-MMD-NJK Document 95 Filed 05/07/20 Page 8 of 14 1 (i) Employees of third-party contractors of the Parties involved solely in providing 2 copying or litigation support services such as organizing, filing, coding, converting, storing, or 3 retrieving Material; 4 (j) Any other person agreed to in writing by the Disclosing Party; and 5 (k) Any other person by order of the Court, after notice to all Parties. 6 5. Any Material that is designated Sensitive-Attorney Eyes Only shall not be disclosed 7 to any person or entity other than the following, and only after such person or entity has been 9 (a) Counsel of record for the Parties; 10 (b) Members of the legal, paralegal, secretarial or clerical staff of such counsel who are 11 assisting in or responsible for working on this action; 10001 Park Run Drive Las Vegas, Nevada 89145 (702) 382-0711 FAX: (702) 382-5816 MARQUIS AURBACH COFFING 8 advised of and has agreed to be subject to the terms of this Order: 12 (c) The Court, its staff, the jury, and all appropriate courts of appellate jurisdiction and 13 their staff; 14 (d) Independent experts or consultants retained by a party or counsel of records for 15 purposes of this litigation, and any employees, associates, or independent contractors retained by 16 those experts or consultants in their work in this litigation; 17 (e) Court reporters during depositions or hearings; 18 (f) Deponents during depositions or witnesses during hearings; 19 (g) Persons who have had, or whom any counsel for any party in good faith believes to 20 have had, prior access to the Sensitive-Attorney Eyes Only Material being disclosed, or who have 21 been participants in a communication that is the subject of the Sensitive-Attorney Eyes Only 22 Material and from whom verification of or other information about that access or participation is 23 sought, solely to the extent of disclosing such information to which they have or may have had 24 access or that is the subject of the communication in which they have or may have participated, 25 except that, unless and until counsel confirms that any such persons have had access or were 26 participants, only as much of the information may be disclosed as may be necessary to confirm the 27 person’s access or participation; Page 8 of 14 MAC:16072-001 4039816_1 5/6/2020 1:07 PM Case 2:18-cv-02361-MMD-NJK Document 95 Filed 05/07/20 Page 9 of 14 1 (h) Employees of third-party contractors of the Parties involved solely in providing 2 copying or litigation support services such as organizing, filing, coding, converting, storing, or 3 retrieving Material; 4 (i) Any other person agreed to in writing by the Disclosing Party; and 5 (j) Any other person by order of the Court, after notice to all Parties. 6 6. Prior to disclosure of any Confidential or Sensitive-Attorney Eyes Only Material to 7 any persons under Section IV(A)(4)(e), (g), (i)-(k), or Section IV(A)(5)(d), (f), (h)-(j), he or she 8 must first be advised of and agree in writing to be bound by the provisions of this Order. Such 9 written agreement shall consist of his or her endorsement of a copy of this Order or of the 11 upon written request. 10001 Park Run Drive Las Vegas, Nevada 89145 (702) 382-0711 FAX: (702) 382-5816 MARQUIS AURBACH COFFING 10 Undertaking attached to this Order. Copies of such writings shall be produced to other parties 12 7. The recipient of any Confidential or Sensitive-Attorney Eyes Only Material shall 13 maintain such Material in a secure and safe area and shall exercise the same standard of due and 14 proper care with respect to the storage, custody, use, and/or dissemination of such information as is 15 exercised by the recipient with respect to its own confidential information. 16 V. INADVERTENT DISCLOSURE OF PRIVILEGED MATERIAL 17 1. The inadvertent production by a Party of Material subject to the attorney-client 18 privilege, work-product protection, or any other applicable privilege or protection, despite the 19 Disclosing Party’s reasonable efforts to prescreen such Material prior to production, will not waive 20 the applicable privilege and/or protection if a request for return of such inadvertently produced 21 Material is made promptly after the Disclosing Party learns of its inadvertent production. 22 2. Upon a request from any Disclosing Party who has inadvertently produced Material 23 that it believes is privileged and/or protected, each Receiving Party shall immediately return such 24 Material and all copies, including those that have been shared with experts, consultants, and 25 vendors, to the Disclosing Party, except for any pages containing privileged markings by the 26 Receiving Party which shall instead be destroyed and certified as such by the Receiving Party to 27 Page 9 of 14 MAC:16072-001 4039816_1 5/6/2020 1:07 PM Case 2:18-cv-02361-MMD-NJK Document 95 Filed 05/07/20 Page 10 of 14 1 the Disclosing Party. Each Receiving Party shall confirm in writing that all such documents or 2 information have been returned or destroyed within five (5) business days of the request. 3 3. Nothing herein shall prevent the Receiving Party from preparing a record for its 4 own use containing the date, author, addresses, and topic of the inadvertently produced Material 5 and such other information as is reasonably necessary to identify the Material and describe its 6 nature to the Court in any motion to compel production of the Material. Any motion to compel 7 production of the Material shall be filed under seal and shall not assert as a ground for production 8 the fact of the inadvertent or unintentional production, nor shall the motion disclose or otherwise 9 use the content of the inadvertently or unintentionally produced document or information in any 11 the Court. 10001 Park Run Drive Las Vegas, Nevada 89145 (702) 382-0711 FAX: (702) 382-5816 MARQUIS AURBACH COFFING 10 way beyond that which is reasonably necessary to identify the Material and describe its nature to 12 VI. 13 INADVERTENT DISCLOSURE OF CONFIDENTIAL OR SENSITIVEATTORNEY EYES ONLY MATERIAL NOT AUTHORIZED UNDER PROTECTIVE ORDER 14 1. In the event of a disclosure of any Material designated under this Order, to any 15 person(s) not authorized to receive such disclosure, the Party responsible for having made such 16 disclosure, and each Party with knowledge thereof, shall immediately notify counsel for the 17 Disclosing Party whose Material has been disclosed and provide to such counsel all known 18 relevant information concerning the nature and circumstances of the disclosure. The responsible 19 Disclosing Party shall also promptly take all reasonable measures to retrieve the improperly 20 disclosed Material and to ensure that no further or greater unauthorized disclosure and/or use 21 thereof is made. 22 2. Unauthorized or inadvertent disclosure does not change the status of the Material or 23 waive the right to hold the disclosed document or information as Protected. 24 VII. OTHER PROVISIONS 25 1. In the event a Receiving Party who has received Confidential or Sensitive-Attorney 26 Eyes Only Material that is subject to this Order is: (a) subpoenaed in another action, (b) served 27 with a request in another action to which the person is a party, or (c) served with any other legal Page 10 of 14 MAC:16072-001 4039816_1 5/6/2020 1:07 PM Case 2:18-cv-02361-MMD-NJK Document 95 Filed 05/07/20 Page 11 of 14 1 process by one not a Party to this action, that seeks Confidential or Sensitive-Attorney Eyes Only 2 Material, he, she, or it shall give prompt written notice of the receipt of such subpoena, demand, or 3 other legal process to the Designating Party and its counsel, and, upon request, shall cooperate with 4 the Designating Party in its efforts to obtain an appropriate court order protecting the Confidential 5 or Sensitive-Attorneys Eyes Only Material. 6 2. Any third party producing Materials in this action may be included in this Order by 7 endorsing a copy of this Order and delivering it to the Requesting Party, who, in turn, will serve a 8 copy of it upon counsel for the other Party. 9 3. This Order shall not prevent any Party from applying to the Court for further or 11 subject to the approval of the Court. 10001 Park Run Drive Las Vegas, Nevada 89145 (702) 382-0711 FAX: (702) 382-5816 MARQUIS AURBACH COFFING 10 additional confidentiality orders, or from agreeing with the other Party to modify this Order, 12 4. This Order shall not preclude any Party from enforcing its rights against any other 13 Party, or any non-party, believed to be violating its rights under this Order. 14 5. Except as provided for in this Order, nothing in this Order, nor any actions taken 15 pursuant to this Order, shall be deemed to have the effect of an admission or waiver by any Party, 16 including the right of either Party to object to the subject matter of any discovery request or the 17 relevance of any evidence. Also, nothing in this Order or any actions under the provisions of this 18 Order shall have the effect of proving, suggesting to prove, or otherwise creating a presumption 19 that information disclosed in this action is confidential, trade secret, or proprietary, as it pertains to 20 the Parties’ respective claims in this action. 21 6. After final termination of this case, including any appeals, each counsel of record, 22 upon written request within 60 days of the date of final termination, shall within 60 days of such 23 request, (a) destroy, or (b) assemble and return to the counsel of record, all Material in their 24 possession and control, embodying Material designated Confidential or Sensitive-Attorneys Eyes 25 Only, including all copies thereof except that each counsel of record may maintain one archive 26 copy of all pleadings, correspondence, deposition transcripts, deposition exhibits, document 27 productions, written discovery answers, trial transcripts, and trial exhibits, together with any Page 11 of 14 MAC:16072-001 4039816_1 5/6/2020 1:07 PM Case 2:18-cv-02361-MMD-NJK Document 95 Filed 05/07/20 Page 12 of 14 1 attorney work product provided that such archive copy is appropriately marked as Confidential or 2 Sensitive-Attorneys Eyes Only and is retained in accordance with the terms of this Order. 3 Notwithstanding the foregoing, counsel for the Parties are not required to destroy counsel’s email 4 communications (and corresponding attachments) related to this case, regardless of whether such 5 email communications contains Material designated Confidential or Sensitive-Attorneys Eyes 6 Only. 7 7. Counsel for any Party may exclude from the room at a deposition, during any 8 questioning that involves Confidential or Sensitive-Attorneys Eyes Only Material, any person 9 (other than the witness then testifying) who is not permitted the disclosure of such Material under 11 / / / 10001 Park Run Drive Las Vegas, Nevada 89145 (702) 382-0711 FAX: (702) 382-5816 MARQUIS AURBACH COFFING 10 this Order. 12 / / / 13 / / / 14 / / / 15 / / / 16 / / / 17 / / / 18 / / / 19 / / / 20 / / / 21 / / / 22 / / / 23 / / / 24 / / / 25 / / / 26 / / / 27 / / / Page 12 of 14 MAC:16072-001 4039816_1 5/6/2020 1:07 PM Case 2:18-cv-02361-MMD-NJK Document 95 Filed 05/07/20 Page 13 of 14 1 8. The Parties and any other person subject to the terms of this Protective Order agree 2 that this Court has and retains jurisdiction during and after this action is terminated for the purpose 3 of enforcing this Order. This Order shall survive termination of this litigation, to the extent that the 4 Confidential or Sensitive-Attorneys Eyes Only Material is not or does not become known to the 5 public. 6 Dated this 6th day of May, 2020. 7 Dated this 6th day of May, 2020. MARQUIS AURBACH COFFING THE VERSTANDIG LAW FIRM, LLC 8 9 By: 11 10001 Park Run Drive Las Vegas, Nevada 89145 (702) 382-0711 FAX: (702) 382-5816 MARQUIS AURBACH COFFING 10 12 13 /s/ Jared M. Moser Nick D. Crosby, Esq. Nevada Bar No. 8996 Jared M. Moser, Esq. Nevada Bar No. 13003 10001 Park Run Drive Las Vegas, Nevada 89145 Attorneys for Defendants, INTU Corporation and Deanna Edwards By: /s/ Maurice VerStandig Maurice VerStandig, Esq. Nevada Bar No. 15346 1452 W. Horizon Ridge Pkwy, #665 Henderson, NV 89012 Attorney for Plaintiffs Krystal Johnson and Elizabeth Spangler 14 15 16 ORDER 7 day of ______________, IT IS HEREBY ORDERED this ____ 2020. May 17 18 UNITED STATES MAGISTRATE JUDGE 19 20 21 22 23 24 25 26 27 Page 13 of 14 MAC:16072-001 4039816_1 5/6/2020 1:07 PM Case 2:18-cv-02361-MMD-NJK Document 95 Filed 05/07/20 Page 14 of 14 1 2 UNDERTAKING I, ___________________________________, have read and agree to be bound by the 3 Protective Order in Johnson et al. v. INTU et al., pending in the United State District Court, 4 District of Nevada, Case Number 2:18-cv-02361-MMD-NJK. I hereby submit to the jurisdiction 5 of the Court for purposes of ensuring compliance with the Protective Order. 6 7 Date: ________________________________ 8 9 Signature: _____________________________ 11 10001 Park Run Drive Las Vegas, Nevada 89145 (702) 382-0711 FAX: (702) 382-5816 MARQUIS AURBACH COFFING 10 Printed Name: __________________________ 12 13 Address: ______________________________ 14 ______________________________ 15 16 17 18 19 20 21 22 23 24 25 26 27 Page 14 of 14 MAC:16072-001 4039816_1 5/6/2020 1:07 PM
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