Farmers Edge Inc. et al v. Farmobile, LLC et al

Filing 77

PROTECTIVE ORDER adopting the parties' Stipulation and Joint Motion for Protective Order and ESI Protocol Governing the Disclosure and Use of Discovery Materials 76 . (Attachment: # 1 Exhibit A - Written Assurance) Ordered by Magistrate Judge Thomas D. Thalken. (TRL)

EXHIBIT A
WRITTEN ASSURANCE
____________________________ declares that:
I reside at ____________________________in the city of ________________ ,
Country _____________________________, State of __________________________;
I am currently employed by ____________________________________ located
at ______________________ and my current job title is ________________________.
I have read and believe I understand the terms of the Protective Order dated
October 24, 2016, filed in Civil Action No. 8:16CV191, pending in the United States
District Court for the District of Nebraska. I agree to comply with and be bound by the
provisions of the Protective Order. I understand that any violation of the Protective
Order may subject me to sanctions by the Court. The undersigned also acknowledges
and confirms that Confidential Information shall not in any way be used in connection
with services performed for the competitor of any party.
Prior to undertaking this engagement, I have conducted an investigation and
confirmed that am not presently a competitor of or working for a competitor of the
Producing or Designating Party. As used herein, any competitor of the parties shall,
solely for the purposes of this protective order, be deemed persons or entities involved
in the research, development or manufacture of technology for automated systems and
methods for capturing farming operation data in real time using CANbus data collection
devices, to process, share, and foster analysis of agronomic data.
I shall not divulge any documents, or copies of documents, designated
“CONFIDENTIAL” or “CONFIDENTIAL – ATTORNEYS’ EYES ONLY” OR
“CONFIDENTIAL SOURCE CODE – ATTORNEYS’ EYES ONLY” obtained pursuant to
such Protective Order, or the contents of such documents, to any person other than
those specifically authorized by the Protective Order. I shall not copy or use such
documents except for the purposes of this action and pursuant to the terms of the
Protective Order.
As soon as practical, but no later than 30 days after final termination of this
action, I shall return to the attorney from whom I have received them, any documents in
my possession designated “CONFIDENTIAL” OR “CONFIDENTIAL - ATTORNEYS’
EYES ONLY” or “CONFIDENTIAL SOURCE CODE – ATTORNEYS’ EYES ONLY,” and
all copies, excerpts, summaries, notes, digests, abstracts, and indices relating to such
documents.
I submit myself to the jurisdiction of the United States District Court for the
District of Nebraska for the purpose of enforcing or otherwise providing relief relating to
the Protective Order.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on _______________________
(Date)

______________________________
(Signature)