Healthy Companion Corp., et al v. Cooper
Filing
42
PROTECTIVE ORDER granting 41 Stipulation. Ordered by Magistrate Judge Cheryl R. Zwart. (Zwart, Cheryl)
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF NEBRASKA
HEALTHY COMPANION CORP., a Nevada
corporation, PALA-TECH LABORATORIES
INC., a Nebraska corporation, QUALITY
ANIMAL CARE MANUFACTURING, INC.,
a Nebraska corporation,
Case No. 4:14-cv-3176-JMG-CRZ
STIPULATED PROTECTIVE ORDER
Plaintiffs,
v.
RAYMOND L. COOPER, Individually,
Defendant/Third Party Plaintiff,
v.
DANIEL BOLTON, Individually,
Third Party Defendant.
WHEREAS, discovery in the above-captioned action may involve the production of
documents and information which the parties claim to be confidential and the parties desire to
pursue discovery with a minimum of delay and expense.
Pursuant to Federal Rules of Civil Procedure and in the interest of efficiency and judicial
economy, particularly in the interest of avoiding significant ancillary litigation of discovery
issues relating to confidential commercial and/or proprietary information, the undersigned
Plaintiffs, Defendant/Third-Party Plaintiff and Third-Party Defendant do hereby stipulate and
agree to this protective order and the procedures set forth herein for designating and protecting
confidential commercial and/or proprietary information. The Parties stipulate as follows:
1.
This Stipulated Protective Order (“Order”) shall apply to and govern all
depositions, documents, information or things disclosed or produced in response to a party’s
informal request, requests for production of documents, answers to interrogatories, responses to
requests for admissions and all other discovery taken under the Federal Rules of Civil Procedure,
and other information which the disclosing party designates as “CONFIDENTIAL,” furnished,
directly or indirectly, by or on behalf of any party or any non-party in connection with the abovecaptioned litigation.
2.
When used in this Order, the phrase “disclosing party” shall refer to the parties to
the above-captioned litigation or to non-parties who give testimony or produce documents or
other material.
3.
When used in this Order, the word “document” encompasses, but is not limited to,
any type of document or testimony, including all documents or things described in Federal Rule
of Evidence 1001(a)-(e) and/or Rule 34(a)(1)(A) or (B).
4.
The disclosing party who designates any material “CONFIDENTIAL” or
“CONFIDENTIAL-ATTORNEYS’ EYES ONLY” (sometimes referred to herein as a
“designating party”) bears the burden of establishing the “CONFIDENTIAL” status of such
material in any situation in which the designation is at issue, and nothing in this Order shall be
construed to alter such burden. The parties enter into and stipulate to this Order without prejudice
to the rights of any party to assert or contest the “CONFIDENTIAL” status of any material as set
forth below.
5.
A disclosing party may designate as “CONFIDENTIAL” any trade secret or other
confidential research, development, or commercial information, as such terms are used in Rule
26(c)(1)(G) and any applicable case law interpreting Rule 26(c)(1)(G). In addition, a disclosing
party may designate as “CONFIDENTIAL” non-public personal information or other
information for which applicable federal or state law requires or allows confidential treatment. A
disclosing party may designated information as “CONFIDENTIAL-ATTORNEYS’ EYES
2
ONLY” if the designating party reasonably believes that such materials and such information are
so confidential that their dissemination should be limited to those persons described in Paragraph
9 below.
6.
In
designating
material
as
“CONFIDENTIAL”
or
“CONFIDENTIAL-
ATTORNEYS’ EYES ONLY,” a disclosing party shall make such a designation only as to
material which it in good faith believes is confidential.
7.
Any party or non-party receiving any non-public material from a disclosing party,
regardless of whether such material is designated as “CONFIDENTIAL” or “CONFIDENTIALATTORNEYS’ EYES ONLY,” shall use that material solely for the purpose of conducting this
litigation, pending in the United States District Court for the District of Nebraska, captioned
Healthy Companion Corp., et. al v. Raymond L. Cooper v. Daniel Bolton, Case No. 14-cv-3176,
and not for any other purpose whatsoever. However, the foregoing shall not limit any party who
is also an officer, director, or shareholder in any of the named companies from exercising or
fulfilling the legal rights, duties, and obligations attendant to those positions.
8.
In the absence of written permission from the disclosing party, or an order of the
Court, material designated as “CONFIDENTIAL” may be disclosed only to the following
persons:
(a)
The attorneys and their support staff working on the above-captioned
litigation on behalf of any party;
(b)
The named parties, including designated company representatives Dan
Bolton and Echo Bell for Plaintiffs and individuals consulting with or advising any party
to the above-captioned litigation, stenographic and clerical employees and contractors
3
working under the direct supervision of counsel, all of which shall sign the
“ACKNOWLEDGMENT” attached hereto as Exhibit “A;”
(c)
Any expert or consultant who is expressly retained by any attorney
described in Paragraph 8(a) to assist in the above-captioned litigation, with disclosure
only to the extent reasonably necessary to perform such work, which expert or consultant
shall sign the “ACKNOWLEDGMENT” attached hereto as Exhibit “A;”
(d)
Any fact witness, including named parties, provided, however, that the
witness (i) shall be permitted to use any documents marked as “CONFIDENTIAL” only
in preparation for and during depositions, hearings and trial, (ii) shall be informed, prior
to being shown materials marked as “CONFIDENTIAL” that he/she is being shown such
materials solely for use in this litigation and (iii) shall sign the “ACKNOWLEDGMENT”
attached hereto as Exhibit “A;”
(e)
Any individual who either prepared the document or is identified on the
face of the document as an addressee or copy addressee;
(f)
Any other person upon order of the Court or upon prior written consent of
the disclosing party; and
(g)
The Court, jury, court personnel, court reporters, and other persons
connected with the Court.
9.
In the absence of written permission from the disclosing party, or an order of the
Court, material designated as “CONFIDENTIAL-ATTORNEYS’ EYES ONLY” may be
disclosed only to the following persons:
(a)
The attorneys and their support staff working on the above-captioned
litigation on behalf of any party;
4
(b)
Any expert or consultant who is expressly retained by any attorney
described in Paragraph 8(a) to assist in the above-captioned litigation, with disclosure
only to the extent reasonably necessary to perform such work, which expert or consultant
shall sign the “ACKNOWLEDGMENT” attached hereto as Exhibit “A;”
(c)
Any other person upon order of the Court or upon prior written consent of
the disclosing party; and
(d)
The Court, jury, court personnel, court reporters, and other persons connected
with the Court.
10.
The persons described in Paragraphs 8(a)-(f) and 9(a)-(d) shall have access to
“CONFIDENTIAL” and/or “CONFIDENTIAL-ATTORNEYS’ EYES ONLY” material only
after they have been made aware of the provisions of this Order (including, without limitation,
Paragraph 7). Counsel shall retain copies of the signed “ACKNOWLEDGMENT” forms until
the completion of the above-captioned litigation. Any person receiving “CONFIDENTIAL”
and/or “CONFIDENTIAL-ATTORNEYS’ EYES ONLY” material is enjoined from disclosing
that material to any other person, except in conformance with this Order. The parties shall act in
good faith to eliminate, whenever possible, the expenditure of “on the record” time to effectuate
or confirm compliance with this Paragraph at any deposition.
11.
A list shall be maintained by counsel for the parties hereto of the names of all
persons, except for counsel and their support personnel, to whom any “CONFIDENTIAL”
and/or “CONFIDENTIAL-ATTORNEYS’ EYES ONLY” material is disclosed, or to whom the
information contained therein is disclosed. Upon a good faith showing by a party that this Order
has been violated, the Court may review such lists if necessary and appropriate to address or
resolve the purported violation.
5
12.
This Court shall retain jurisdiction over this Order, including any proceedings
relating to performance under or compliance with the Order. Individuals who receive
“CONFIDENTIAL” and/or “CONFIDENTIAL-ATTORNEYS’ EYES ONLY” material shall be
subject to this Order and to the jurisdiction of this Court concerning this Order.
13.
The
recipient
of
any
“CONFIDENTIAL”
and/or
“CONFIDENTIAL-
ATTORNEYS’ EYES ONLY” material that is provided under this Order shall maintain such
material in a secure and safe area and shall exercise the same standard of due and proper care
with respect to the storage, custody, use and/or dissemination of such material as is exercised by
the recipient with respect to its own proprietary material. “CONFIDENTIAL” material shall not
be copied, reproduced, summarized, extracted or abstracted, except to the extent that such
copying, reproduction, summarization, extraction or abstraction is reasonably necessary for the
conduct of this lawsuit. All such copies, reproductions, summarizations, extractions, and
abstractions shall be subject to the terms of the Order and labeled in the same manner as the
designated material on which they are based.
14.
Disclosing parties shall designate “CONFIDENTIAL” and/or “CONFIDENTIAL-
ATTORNEYS’ EYES ONLY” material as follows:
(a)
In the case of documents, interrogatory answers, responses to requests for
admissions, and the information contained therein, designation shall be made, as
appropriate under the terms of this Stipulation and Order, by placing the following legend
on each page of any such document: “CONFIDENTIAL” and/or “CONFIDENTIALATTORNEYS’ EYES ONLY.” In the event that a disclosing party inadvertently fails to
stamp or otherwise designate a document or other material as “CONFIDENTIAL” and/or
“CONFIDENTIAL-ATTORNEYS’ EYES ONLY” at the time of its production, that
6
disclosing party may stamp or otherwise designate the document or other material as
“CONFIDENTIAL” and/or “CONFIDENTIAL-ATTORNEYS’ EYES ONLY” at any
reasonable time thereafter. The delay in designating a document as “CONFIDENTIAL”
and/or “CONFIDENTIAL-ATTORNEYS’ EYES ONLY” shall not, in and of itself, be
deemed to have effected a waiver of any of the protections of this Order, but such
document or other material shall be treated as “CONFIDENTIAL” and/or
“CONFIDENTIAL-ATTORNEYS’ EYES ONLY” only beginning at the time such
designation occurs, provided, however, that the foregoing provision shall not apply to any
documents or material that had already been made publicly available prior to the
designation.
(b)
“CONFIDENTIAL” and/or “CONFIDENTIAL-ATTORNEYS’ EYES
ONLY” material may be used in depositions. Designation of the portion of the deposition
transcript
(including
exhibits)
that
contains
“CONFIDENTIAL”
and/or
“CONFIDENTIAL-ATTORNEYS’ EYES ONLY” material shall be made by a statement
to such effect on the record in the course of the deposition or, upon review of such
transcript, by the disclosing party or counsel for the disclosing party to whose
“CONFIDENTIAL” and/or “CONFIDENTIAL-ATTORNEYS’ EYES ONLY” material
the deponent has had access, which shall be so designated within twenty one (21) days
after the deposition transcript is provided to the Parties. Prior to the Parties receiving a
copy of the transcript, the entire deposition transcript, including exhibits, shall be deemed
“CONFIDENTIAL and/or “CONFIDENTIAL-ATTORNEYS’ EYES ONLY”.”
(c)
Any
“CONFIDENTIAL”
and/or
“CONFIDENTIAL-ATTORNEYS’
EYES ONLY” material produced in a non-paper media (e.g., videotape, audiotape,
7
computer disc, etc.) may be designated as such by labeling the outside of such non-paper
media as “CONFIDENTIAL” and/or “CONFIDENTIAL-ATTORNEYS’ EYES ONLY”
and producing this material in a sealed envelope. In the event a receiving party generates
any electronic copy, “hard copy,” transcription, or printout from any such designated
non-paper media, such party must treat each copy, transcription, or printout as
“CONFIDENTIAL” pursuant to the terms of this Order.
15.
Nothing in this Order shall be taken as indicating that any information is in fact
“CONFIDENTIAL” and/or “CONFIDENTIAL-ATTORNEYS’ EYES ONLY” or entitled to
confidential treatment. No party shall be obligated to challenge the propriety of a
“CONFIDENTIAL” and/or “CONFIDENTIAL-ATTORNEYS’ EYES ONLY” designation at
the time made, and a failure to do so shall not preclude a subsequent challenge thereto, nor shall
a party that has designated materials or information as “CONFIDENTIAL” and/or
“CONFIDENTIAL-ATTORNEYS’ EYES ONLY” contend that any delay by another party in
objecting to
the designating party’s
“CONFIDENTIAL”
and/or
“CONFIDENTIAL-
ATTORNEYS’ EYES ONLY” designation in any way (a) lends support to the designating
party’s
“CONFIDENTIAL”
and/or
“CONFIDENTIAL-ATTORNEYS’
EYES
ONLY”
designation or (b) invalidates or diminishes in any way the objecting party’s challenge of the
“CONFIDENTIAL” and/or “CONFIDENTIAL-ATTORNEYS’ EYES ONLY” designation for
any such materials or information. In the event that any party disagrees at any stage of these
proceedings with such designation, counsel for such party shall notify counsel for the disclosing
party in writing (the “Notice”). The objecting party shall identify each particular document
bearing a designation to which it objects and shall specify the reason(s) for the objection,
provided that the party challenging the “CONFIDENTIAL” and/or “CONFIDENTIAL-
8
ATTORNEYS’ EYES ONLY” designation may identify multiple documents by Bates number
(whether in a range of consecutive numbers or otherwise) in its Notice when the reason or
reasons for challenging the “CONFIDENTIAL” and/or “CONFIDENTIAL-ATTORNEYS’
EYES ONLY” designation apply in the same manner to the documents identified in the Notice.
Within seven (7) calendar days of the receipt of the Notice, counsel for the parties (and any nonparty involved) shall promptly schedule a date and time to meet and confer to attempt to resolve
such dispute in good faith on an informal basis consistent with the requirement to confer in good
faith under Rule 26(c)(1) and Rule 37(a)(1). If the dispute cannot be resolved, the party that
designated the materials in question as “CONFIDENTIAL” and/or “CONFIDENTIALATTORNEYS’ EYES ONLY” may request appropriate relief from the Court, and the objecting
party may also request any relief from the Court that it deems appropriate (which shall have first
been raised no later than during the parties’ meet and confer session(s)) in its opposition to the
designating party’s motion or other proposed method of seeking relief from the Court. The
materials in question shall retain their “CONFIDENTIAL” and/or “CONFIDENTIALATTORNEYS’ EYES ONLY” status until the Court rules on any such motion so long as the
party
that
designated
the
materials
in
question
as
“CONFIDENTIAL”
and/or
“CONFIDENTIAL-ATTORNEYS’ EYES ONLY” seeks relief from the Court within: (i) thirty
(30) days of the date the parties initially met and conferred, if the disagreement pertains to fewer
than ten documents; or (ii) forty five (45) days of the date the parties initially met and conferred,
if the disagreement pertains to ten or more documents. The parties (and any non-party involved)
may agree to extend the time for the disclosing party to apply to the Court for relief. If the
designating party does not apply to the Court for a ruling on the designation of discovery
material as “CONFIDENTIAL” and/or “CONFIDENTIAL-ATTORNEYS’ EYES ONLY”
9
within the time period prescribed herein or agreed to by the parties, the discovery material will
no longer be deemed “CONFIDENTIAL and/or “CONFIDENTIAL-ATTORNEYS’ EYES
ONLY”.” The designating party may request a telephonic hearing with respect to the
“CONFIDENTIAL” status of materials.
Nothing in this Order shall alter the burden on the disclosing party to establish the
“CONFIDENTIAL” and/or “CONFIDENTIAL-ATTORNEYS’ EYES ONLY” status of
information it has so designated.
16.
Documents
containing
“CONFIDENTIAL”
and/or
“CONFIDENTIAL-
ATTORNEYS’ EYES ONLY” material shall not be filed with the Court unless the filing party
reasonably believes it is necessary to do so for purposes of trial, motions (including without
limitation, motions for preliminary injunction or summary judgment) or other Court matters. A
party seeking to file “CONFIDENTIAL” and/or “CONFIDENTIAL-ATTORNEYS’ EYES
ONLY” material must follow the procedures set forth in NECivR 7.5 or NECivR 5.3(c) so that
they are filed under seal or with restricted access.
17.
In the event that any “CONFIDENTIAL”
and/or “CONFIDENTIAL-
ATTORNEYS’ EYES ONLY” material is used in any Court proceeding in connection with this
litigation, it shall not lose its “CONFIDENTIAL” and/or “CONFIDENTIAL-ATTORNEYS’
EYES ONLY” status through such use, and the parties shall take all steps reasonably required to
protect its confidentiality during such use. In particular, while a motion to seal is pending and
before the Court has ruled, no party shall make use in open court of any documents that are
subject to that motion to seal without the consent of the designating party or the permission of
the Court.
10
18.
If “CONFIDENTIAL” and/or “CONFIDENTIAL-ATTORNEYS’ EYES ONLY”
material is disclosed to any person other than in the manner authorized by this Order, the person
or party responsible for the disclosure must seasonably bring all pertinent facts relating to such
disclosure to the attention of all attorneys of record in the above-captioned action and, without
prejudice to any other rights and remedies of the parties or non-parties, make every effort to
prevent further disclosure by it or by the person who was the recipient of such material.
19.
Nothing in this Order shall preclude any parties or non-parties to the lawsuit or
their attorneys (a) from showing a document or part of a document designated as
“CONFIDENTIAL” and/or “CONFIDENTIAL-ATTORNEYS’ EYES ONLY” to an individual
who either prepared the document or is identified on the face of the document as an addressee or
copy addressee, or (b) from disclosing or using, in any manner or for any purpose, any material
or documents from the disclosing party’s own files which the disclosing party itself has
designated as “CONFIDENTIAL and/or “CONFIDENTIAL-ATTORNEYS’ EYES ONLY”.”
20.
In the event any receiving party having possession, custody or control of any
“CONFIDENTIAL” and/or “CONFIDENTIAL-ATTORNEYS’ EYES ONLY” material receives
a subpoena, request for production of documents, or other process or order to produce such
material in another, unrelated legal proceeding, from a non-party to the above-captioned
litigation, such receiving party shall:
(a)
give prompt written notice of the subpoena, request for production of
documents, or other process or order to counsel for the disclosing party that designated
the material as “CONFIDENTIAL” and/or “CONFIDENTIAL-ATTORNEYS’ EYES
ONLY”;
11
(b)
furnish counsel for that disclosing party with a copy of said subpoena,
request for production of documents, or other process or order; and
(c)
cooperate with respect to all reasonable and legitimate procedures sought
to be pursued by the disclosing party whose interests may be affected.
The
disclosing
party
asserting
the
“CONFIDENTIAL”
and/or
“CONFIDENTIAL-
ATTORNEYS’ EYES ONLY” treatment shall have the burden of defending against such
subpoena, process or order. The party receiving the subpoena, request for production of
documents, or other process or order shall be entitled to comply with it except to the extent the
disclosing party asserting the “CONFIDENTIAL” and/or “CONFIDENTIAL-ATTORNEYS’
EYES ONLY” treatment is successful in obtaining an order modifying or quashing the subpoena,
request for production of documents, or other process or order, provided, however, that the party
receiving the subpoena, request for production of documents, or other process shall await the
disposition of any motion to quash or motion for a protective order timely filed by the disclosing
party before producing any “CONFIDENTIAL” and/or “CONFIDENTIAL-ATTORNEYS’
EYES ONLY” information in response to the subpoena, request for production of documents, or
other process or order unless a court orders compliance with the subpoena, request for
production or other process, or unless awaiting the disposition of any motion to quash or motion
for protective order may subject the party receiving the discovery request to sanctions or being
held in contempt of court.
21.
The inadvertent production in the course of discovery in the above-captioned
litigation of any documents or material (whether designated as “CONFIDENTIAL” and/or
“CONFIDENTIAL-ATTORNEYS’ EYES ONLY” or not) shall not be deemed to waive
whatever attorney client privilege, work product protection or other privilege or immunity that
12
would otherwise attach to those documents or material produced or to other documents or
material, so long as the disclosing party notifies the other party or parties of the claim of
privilege or other protection or immunity. Upon receipt of such notice, all other parties shall
(regardless of whether they agree with the disclosing party’s claim of privilege or protection)
promptly:
(a)
destroy or segregate all copies of the inadvertently produced documents or
material in such party’s possession, custody, or control, and notify the disclosing party
that it has done so; and
(b)
notify the disclosing party that reasonable steps have been taken to
retrieve and/or destroy the inadvertently produced documents or material from other
persons to whom such documents or material have been provided, if any, consistent with
Rule 26(b)(5)(B). Compliance with this Paragraph 21 does not, and shall not be deemed
to, constitute agreement that the claimed document or material is in fact privileged or
entitled to protection or immunity.
22.
The parties shall comply with their ethical and legal obligations concerning the
actual or apparent inadvertent production of privileged or protected information, including by
notifying promptly a disclosing party when appropriate.
23.
Within sixty (60) days of the termination of litigation between the parties,
including final appellate action or the expiration of time to appeal or seek further review, all
“CONFIDENTIAL” and/or “CONFIDENTIAL-ATTORNEYS’ EYES ONLY” material
produced by a disclosing party, and all copies thereof, shall (at the request of the disclosing
party) be returned to the disclosing party or destroyed. If destroyed, counsel shall certify the
destruction and provide a copy of the certification to the disclosing party. Counsel for each
13
disclosing party shall be entitled to retain all pleadings, motion papers, other court filings
(excluding
materials
designated
as
“CONFIDENTIAL”
and/or
“CONFIDENTIAL-
ATTORNEYS’ EYES ONLY”), legal memoranda, correspondence and work product.
24.
Except as specifically provided herein, the terms, conditions, and limitations of
this Order shall survive the termination of the above-captioned litigation.
25.
This Order is without prejudice to the right of any party or non-party to seek relief
from the Court from any of the provisions contained herein.
26.
This Order shall not be construed as waiving any right to assert a claim of
privilege, relevance, overbreadth, burdensomeness or other grounds for not producing material
called for, and access to all material (whether designated as “CONFIDENTIAL” and/or
“CONFIDENTIAL-ATTORNEYS’ EYES ONLY” or not) shall be only as provided by the
discovery rules and other applicable law.
27.
The parties will abide by all Court orders and statutory provisions (including
applicable law and/or court orders concerning such provisions) concerning the eligibility of each
party to receive documents or other material through discovery. Any party that is eligible to
receive such documents or material shall not provide any documents or material, or information
that is contained in or derived from such documents or material, to any other party unless the
other party also is eligible to receive such documents or material. Nothing in this Paragraph,
however, shall be read to prevent the parties from filing documents in support of or in opposition
to motions in this Court.
DATED this ___ day of February 2015.
February 17, 2015.
BY THE COURT:
BY THE COURT:
____________________________________
_______________________
Hon. Cheryl R. Zwart
Cheryl R. Zwart
United StatesStates Magistrate Judge
United Magistrate Judge
14
Dated this 16th day of February, 2015.
HEALTHY COMPANION CORP., a Nevada
RAYMOND L. COOPER,
corporation, PALA-TECH LABORATORIES
Defendant/Counter-Claimant/Third-Party
INC., a Nebraska corporation, and QUALITY
Plaintiff,
ANIMAL CARE MANUFACTURING, INC., a
Nebraska corporation, Plaintiffs/CounterclaimDefendants,
By: s/ Brian J. Koenig
Brian J. Koenig, #23807
John V. Matson, #25278
KOLEY JESSEN P.C., L.L.O.
One Pacific Place, Suite 800
1125 South 103rd Street
Omaha, NE 68124-1079
(402) 390-9500
(402) 390-9005 (facsimile)
Brian.koenig@koleyjessen.com
John.Matson@koleyjessen.com
By: s/ Sheila A. Bentzen
Robert L. Nefsky, #15449
Sheila A. Bentzen, #25020
REMBOLT LUDTKE LLP
1128 Lincoln Mall, Suite 300
Lincoln, NE 68508
Omaha, NE 68124-1079
(402) 475-5100
(402) 475-5087 (facsimile)
rnefsky@remboltlawfirm.com
sbentzen@remboltlawfirm.com
Attorneys for Plaintiffs/CounterclaimDefendants
Attorneys for Defendant/Counter-Claimant
Third-Party Plaintiff
DANIEL BOLTON, Third-Party Defendant,
By: s/ Scott D. Jochim
Scott D. Jochim, #21956
CROKER, HUCK, KASHER, DEWITT,
ANDERSON & GONDERINGER, L.L.C.
2120 South 72nd Street, Suite 1200
Omaha, NE 68124
(402) 391-6777
(402) 390-9221 (facsimile)
sjochim@crockerlaw.com
Attorneys for Third-Party Defendant
15
EXHIBIT “A”
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF NEBRASKA
HEALTHY COMPANION CORP., a Nevada
corporation, PALA-TECH LABORATORIES
INC., a Nebraska corporation, QUALITY
ANIMAL CARE MANUFACTURING, INC.,
a Nebraska corporation,
Case No. 4:14-cv-3176-JMG-CRZ
ACKNOWLEDGEMENT
Plaintiffs,
v.
RAYMOND L. COOPER, Individually,
Defendant/Third Party Plaintiff,
v.
DANIEL BOLTON, Individually,
Third Party Defendant.
I, _________________________, do hereby acknowledge that I have received and read a
copy of the attached Stipulated Protective Order, and I agree to be bound by the terms of the
Order, and to be subject to the jurisdiction of this Court for enforcement of all terms of the Order
and for judicial action for any violation of the Order.
DATED this ______ day of __________ 201_.
____________________________________
Relationship to this lawsuit: _____________
STATE OF ____________
COUNTY OF __________
)
) ss.
)
Subscribed and sworn to before me this ______ day of __________ 201_.
____________________________________
Notary Public
4812-8347-7026, v. 1
16
Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.
Why Is My Information Online?