Martinez v. Stryker Corporation et al

Filing 15

PROTECTIVE ORDER. Signed by Judge Dana L. Christensen on 7/13/2017. (Attachments: # 1 Exhibit A) (NOS)

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1 UNITED STATES DISTRICT COURT 2 DISTRICT OF MONTANA 3 LORI MARTINEZ, 4 No. 9:17-CV-00002-DLC Plaintiff, 5 vs. 6 HOWMEDICA OSTEONICS CORPORATION, Defendant. 7 8 9 10 EXHIBIT A - AGREEMENT TO MAINTAIN CONFIDENTIALITY The undersigned hereby acknowledges and says: 1. I hereby attest to my understanding that information or documents designated Snell & Wilmer L.L.P. LAW OFFICES One Ariz ona Center, 400 E. Van Buren, Suite 190 0 Phoenix , Arizona 85004-2 202 602.382 .6000 11 “Confidential Discovery Material” are provided to me pursuant to the terms and conditions and 12 restrictions of the Protective Order entered ________________, 2017 (the “Protective Order”), in 13 the above captioned matter, that I have been given a copy of and have read the Order, and that I 14 hereby agree to be bound by its terms. I also understand that my execution of this Agreement to 15 Maintain Confidentiality, indicating my agreement to be bound by the Protective Order, is a 16 prerequisite to my review of any information or documents designated as “Confidential” or 17 “Trade Secret” pursuant to the Protective Order. 18 2. I further agree that I shall not disclose to others, except in accordance with the 19 Protective Order, such Confidential Discovery Material, including notes or other memoranda or 20 writings regarding the Confidential Discovery Material, and that such Confidential Discovery 21 Material shall be used only for the purposes authorized by the Protective Order. 22 3. I further agree and attest to my understanding that my obligation to honor the 23 confidentiality of such information or documents will continue even after the termination of this 24 lawsuit. 25 4. I further agree to return all copies of any Confidential Discovery Material I have 26 received to counsel who provided it to me no later than 30 days after the conclusion of this 27 litigation, or at such other time as provided for by the Protective Order or agreed to by the 28 producing party. - 14 - 1 5. I further agree and attest to my understanding that, in the event that I fail to abide 2 by the terms of the Protective Order, I may be subject to sanctions, including contempt of Court, 3 for such failure and further understand that I may subject myself to personal liability for civil 4 money damages resulting from claims of injury based on the improper disclosure of Confidential 5 Discovery Material. I further agree to be subject to the jurisdiction of the Court for the purpose of 6 any proceedings related to enforcement of the Protective Order. 7 8 9 10 Snell & Wilmer L.L.P. LAW OFFICES One Ariz ona Center, 400 E. Van Buren, Suite 190 0 Phoenix , Arizona 85004-2 202 602.382 .6000 11 12 13 14 ______________________________ Signature ______________________________ Printed Name ______________________________ Street Address, City, State and ZIP ______________________________ Telephone Number 15 16 17 18 19 20 21 22 23 24 25 26 27 28 - 15 -

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