Campagna v. Arroweye Solutions, Inc. et al, No. 2:2021cv00581 - Document 62 (D. Nev. 2023)
Court Description: ORDER Granting 61 Stipulated Protective Order. Signed by Magistrate Judge Cam Ferenbach on 1/10/2023. (Copies have been distributed pursuant to the NEF - JQC)
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Campagna v. Arroweye Solutions, Inc. et al Doc. 62 Case 2:21-cv-00581-JCM-VCF Document 62 Filed 01/10/23 Page 1 of 7 1 HONE LAW Jill Garcia, NV Bar No. 7805 2 jgarcia@hone.law 701 N. Green Valley Parkway, Suite 200 3 Henderson, NV 89074 Phone 702-608-3720 4 Fax 702-608-7814 5 Attorneys for Plaintiff 6 UNITED STATES DISTRICT COURT 7 DISTRICT OF NEVADA 8 JENNIFER CAMPAGNA, an individual, 9 10 Case No. 2:21-cv-00581-JCM-VCF Plaintiff, [PROPOSED] PROTECTIVE ORDER v. 11 ARROWEYE SOLUTIONS, INC., a Delaware corporation; MICA MOSELEY, an individual; 12 DOES I through X, inclusive; and ROE BUSINESS ENTITIES, I through X, inclusive, 13 Defendants. 14 15 16 Plaintiff Jennifer Campagna (“Plaintiff” or “Campagna”) and Defendants Arroweye 17 Solutions, Inc. (“Arroweye”) and Mica Moseley (“Moseley,” collectively “Defendants”), by and 18 through their respective counsel, have agreed to and have submitted to the Court, and for good 19 cause shown the Court hereby enters, the following Protective Order: 20 On or about December 14, 2022, third party The Fletcher Group produced documents 21 pursuant to a Subpoena, bates labeled FLETCHER000001-FLETCHER000108. Included within 22 the documents were a contracts and invoices that contain amounts agreed upon between The 23 Fletcher Group and Arroweye for work performed, as well as invoices containing the amounts 24 invoiced by The Fletcher Group. The Fletcher Group redacted these amounts, as it believes these 25 amounts to be confidential business information. 26 In order to allow The Fletcher Group to provide unredacted information, and still maintain 27 its confidential business information on pricing, the parties enter into this Protective Order. 28 / / / 1 Dockets.Justia.com Case 2:21-cv-00581-JCM-VCF Document 62 Filed 01/10/23 Page 2 of 7 1 It is hereby ordered by the Court that the following restrictions and procedures shall 2 apply to certain information, documents and excerpts from documents supplied by the parties to 3 each other in response to discovery requests: 4 Counsel for The Fletcher Group or Arroweye may designate any document containing 5 confidential business information as confidential if counsel determines, in good faith, that such 6 designation is necessary to protect the interests of the client. Information and documents 7 designated by a party as confidential will be stamped “CONFIDENTIAL.” “Confidential” 8 information or documents may be referred to collectively as “confidential information.” 9 Unless ordered by the Court, or otherwise provided for herein, the Confidential 10 Information disclosed will be held and used by the person receiving such information solely for 11 use in connection with the above-captioned action. 12 In the event a party challenges another party’s confidential designation, counsel shall 13 make a good faith effort to resolve the dispute, and in the absence of a resolution, the challenging 14 party may thereafter seek resolution by the Court. The burden of establishing proper designation 15 as confidential shall be on the party claiming that it is confidential. Nothing in this Protective 16 Order constitutes an admission by any party that Confidential Information disclosed in this case 17 is relevant or admissible. Each party specifically reserves the right to object to the use or 18 admissibility of all Confidential Information disclosed, in accordance with applicable law and 19 Court rules. 20 Information or documents designated as “confidential” shall not be disclosed to any 21 person, except: 22 a. The requesting party and counsel, including in-house counsel; 23 b. Employees of such counsel assigned to and necessary to assist in the litigation; 24 c. Consultants or experts assisting in the prosecution or defense of the matter, to 25 the extent deemed necessary by counsel; 26 d. Any person from whom testimony is taken or is to be taken in these actions, 27 except that such a person may only be shown that Confidential Information 28 during and in preparation for his/her testimony and may not retain the 2 Case 2:21-cv-00581-JCM-VCF Document 62 Filed 01/10/23 Page 3 of 7 1 Confidential Information; and 2 e. The Court (including any clerk, stenographer, or other person having access to 3 any Confidential Information by virtue of his or her position with the Court) or 4 the jury at trial or as exhibits to motions. 5 Prior to disclosing or displaying the Confidential Information to any person, counsel 6 shall: 7 f. inform the person of the confidential nature of the information or documents; 8 and 9 g. inform the person that this Court has enjoined the use of the information or 10 documents by him/her for any purpose other than this litigation and has 11 enjoined the disclosure of that information or documents to any other person. 12 The Confidential Information may be displayed to and discussed with the persons 13 identified in Paragraphs 4(c) and (d) only on the condition that prior to any such display or 14 discussion, each such person shall be asked to sign an agreement to be bound by this Order in the 15 form attached hereto as Exhibit A. In the event such person refuses to sign an agreement in the 16 form attached as Exhibit A, the party desiring to disclose the Confidential Information may seek 17 appropriate relief from the Court. 18 The disclosure of a document or information without designating it as “confidential” shall 19 not constitute a waiver of the right to designate such document or information as Confidential 20 Information provided that the material is designated pursuant to the procedures set forth herein 21 no later than the latter of fourteen (14) days after the close of discovery or fourteen (14) days 22 after the document or information’s production. If so designated, the document or information 23 shall thenceforth be treated as Confidential Information subject to all the terms of this Stipulation 24 and Order. 25 All information subject to confidential treatment in accordance with the terms of this 26 Stipulation and Order that is filed with the Court, and any pleadings, motions or other papers 27 filed with the Court disclosing any Confidential Information, shall be filed under seal to the 28 extent permitted by law (including without limitation any applicable rules of court) and kept 3 Case 2:21-cv-00581-JCM-VCF Document 62 Filed 01/10/23 Page 4 of 7 1 under seal until further order of the Court. To the extent the Court requires any further act by the 2 parties as a precondition to the filing of documents under seal (beyond the submission of this 3 Stipulation and Order Regarding Confidential Information), it shall be the obligation of the 4 producing party of the documents to be filed with the Court to satisfy any such precondition. A 5 party seeking to file a confidential document under seal must file a motion to seal and must 6 comply with LR IA 10-5 and the Ninth Circuit's directives in Kamakana v. City and County of 7 Honolulu, 447 F.3d 1172 (9th Cir. 2006). Where possible, only confidential portions of filings 8 with the Court shall be filed under seal. 9 /// 10 / / / 11 / / / 12 / / / 13 / / / 14 / / / 15 / / / 16 / / / 17 / / / 18 / / / 19 / / / 20 / / / 21 / / / 22 / / / 23 / / / 24 / / / 25 / / / 26 / / / 27 / / / 28 / / / 4 Case 2:21-cv-00581-JCM-VCF Document 62 Filed 01/10/23 Page 5 of 7 1 At the conclusion of litigation, the Confidential Information and any copies thereof shall 2 be promptly (and in no event later than thirty (30) days after entry of final judgment no longer 3 subject to further appeal) returned to the producing party or certified as destroyed, except that the 4 parties’ counsel shall be permitted to retain their working files on the condition that those files 5 will remain confidential. The foregoing is entirely without prejudice to the right of any party to 6 apply to the Court for any further Protective Order relating to confidential information; or to 7 object to the production of documents or information; or to apply to the Court for an order 8 compelling production of documents or information; or for modification of this Order. This 9 Order may be enforced by either party and any violation may result in the imposition of 10 sanctions by the Court. 11 Dated this 9th day of January 2023. Dated this 9th day of January 2023. 12 HONE LAW GORDON REES SCULLY MANSUKHANI, LLP 13 /s/Jill Garcia 14 Jill Garcia, NV Bar No. 7805 jgarcia@hone.law 15 701 N. Green Valley Parkway, Suite 200 Henderson NV 89074 16 Attorneys for Plaintiff 17 Jennifer Campagna 18 /s/Dione C. Wrenn Linh Hua (admitted pro hac vice) Dione C. Wrenn, NV Bar No. 13285 jowens@alversontaylor.com 300 South 4th Street, Ste 1550 Las Vegas, NV 89101 Attorneys for Defendants Arroweye Solution, Inc. and Mica Moseley 19 20 21 22 23 24 IT IS SO ORDERED. 1-10-2023 Dated: _____________________ ____________________________________ UNITED STATES MAGISTRATE JUDGE 25 26 27 28 5 Case 2:21-cv-00581-JCM-VCF Document 62 Filed 01/10/23 Page 6 of 7 EXHIBIT A CONFIDENTIALITY AGREEMENT Case 2:21-cv-00581-JCM-VCF Document 62 Filed 01/10/23 Page 7 of 7 1 EXHIBIT "A" 2 CONFIDENTIALITY AGREEMENT 3 I, _______________________________ do hereby acknowledge and agree as follows: 4 1. I have received and read the Protective Order entered in the matter entitled 5 Campagna v Arroweye Solutions, Inc. et al, Case No. 2:21-cv-00581-JCM-VCF , pending before 6 the United States District Court, District of Nevada, of which the form of this Confidentiality 7 Agreement (“Agreement”) is an attachment. 8 2. I understand the terms and provisions of the Protective Order and agree to be 9 bound by and to strictly adhere to all of its terms and provisions. 10 3. I hereby submit to the jurisdiction of the United States District Court, District of 11 Nevada, solely for the purpose of enforcement of the Protective Order. 12 Dated the ____ day of _________________ 2023. 13 14 ____________________________________ [Signature] 15 16 ____________________________________ 17 ____________________________________ 18 ____________________________________ [Printed Name, Address, Telephone Number] 19 20 21 22 23 24 25 26 27 28 6
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