Cybergun S.A. et al v. JAG Precision

Filing 38

PROTECTIVE ORDER Signed by Magistrate Judge George Foley, Jr on 3/6/2012. (Copies have been distributed pursuant to the NEF - SLR)

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J. Stephen Peek, Esq.
Nevada Bar No. 1758
Michael W. Wadley, Esq.
Nevada Bar No. 12119
HOLLAND & HART LLP
9555 Hillwood Drive, 2nd Floor
Las Vegas, Nevada 89134
702-669-4600
702-669-4650 – fax
[e-mail]
[e-mail]

11

Brett L. Foster, Esq. (pro hac admission)
Richard T. Jackson, Esq. (pro hac admission)
HOLLAND & HART LLP
222 S. Main Street, Suite 2200
Salt Lake City, Utah 84101
801-799-5800
801-799-5700 – fax
[e-mail]
[e-mail]

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Attorneys for Plaintiffs

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HOLLAND & HART LLP

9555 Hillwood Drive, 2nd Floor
Las Vegas, Nevada 89134

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UNITED STATES DISTRICT COURT
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DISTRICT OF NEVADA
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CYBERGUN S.A., a French Corporation, and
16 FN HERSTAL, S.A., a Belgian Corporation,

CASE NO. 2:12-cv-00074-KJD-GWF

17

JOINT MOTION FOR ENTRY OF
STIPULATED PROTECTIVE ORDER

Plaintiffs,

18 v.
19 JAG PRECISION, a California Corporation,
20

Defendant.

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Plaintiffs Cybergun S.A. and FN Herstal, S.A. (“Plaintiffs”) and Defendant Jag Precision

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(“Defendant”) jointly move this Court for entry of a protective order in this case pursuant to Rule

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26(c) of the Federal Rules of Civil Procedure. The parties present the terms of the Stipulated

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Protective Order for the Court’s approval and entry in the form attached hereto as Exhibit A. The

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parties jointly request that the Court enter the Stipulated Protective Order to aid them in handling

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of confidential and proprietary material during the course of this case.

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///
Page 1 of 2
5440854_1.DOCX

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DATED March 2, 2012.

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/s/ Richard T. Jackson, Esq.
J. Stephen Peek, Esq.
Michael W. Wadley, Esq.
HOLLAND & HART LLP
9555 Hillwood Drive, 2nd Floor
Las Vegas, NV 89134

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Brett L. Foster, Esq. (pro hac admission)
Richard T. Jackson, Esq. (pro hac admission)
HOLLAND & HART LLP
222 S. Main Street, Suite 2200
Salt Lake City, UT 84101

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Attorneys for Plaintiffs

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/s/ Thomas I. Rozsa, Esq.

HOLLAND & HART LLP

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9555 Hillwood Drive, 2nd Floor
Las Vegas, Nevada 89134

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(Signed by Filing Attorney with Permission of
Defendant Attorney)

Thomas I. Rozsa, Esq. (Pro Hac Admission)
ROZSA LAW GROUP, LC
18757 Burbank Boulevard, Suite 220
Tarzana, CA 91356

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James A. Kohl, Esq.
HOWARD & HOWARD
3800 Howard Hughes Parkway, Suite 1400
Las Vegas, NV 89169

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Attorneys for Defendant

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Page 2 of 2
5440854_1.DOCX

EXHIBIT A

EXHIBIT A

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

3 CYBERGUN S.A., a French Corporation, and
FN HERS TAL, S.A., a Belgian Corporation,

CASE NO. 2: 12-cv-00074-KJD-GWF

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STIPULATED PROTECTIVE ORDER

Plaintiffs,
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v.
6

JAG PRECISION, a California Corporation,
7

Defendant.
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9

WHEREAS, the parties believe certain information to be revealed in the course of this

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action is of proprietary andlor confidential nature, including sales data, advertising expenses,

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marketing documents, documents relating to the selection of the trademarks at issue, market

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research, and channels oftrade information;

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IT IS HEREBY STIPULATED AND AGREED, by and between the parties, through their

attorneys, and ORDERED BY THE COURT that:
1.

This Agreement applies to all documents, information, electronically stored

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information, tangible things, and testimony disclosed during discovery in this action ("Discovery

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Material") by a party in this action or by a third party ("Disclosing Party") to another party(ies)

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("Receiving Party") including all portions of transcripts of depositions, exhibits, answers to

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interrogatories, responses to requests for admission, documents or things, which are designated by

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the Disclosing Party in accordance herewith as containing or comprising confidential or

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proprietary infonnation within the meaning of Fed. R. Civ. P. 26(c) (hereinafter "Confidential

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Information" and "Highly Confidential Information") as more fully set forth herein.

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2.

"Confidential Information" and "Highly Confidential Information" are intended to

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mean information of the type contemplated by Rule 26 of the Federal Rules of Civil Procedure,

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and which has not been made public by the Disclosing Party and which a Disclosing Party regards

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as proprietary, as more fully defined in Paragraphs 4 and 7.

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3.

Unless the Parties agree in writing otherwise, all Discovery Material containing

Confidential Information or Highly Confidential Information shall be used solely for the
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5422315_2.DOCX

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prosecution or defense of this action. Any such Discovery Material designated as Confidential

2

Information or Highly Confidential Information shall not be used for any business, commercial,

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competitive, personal, or other purpose.

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Information shall not be disseminated to anyone, nor made public, nor used, except as permitted by

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this Protective Order or by order of the Court.

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Disclosing Party in any manner with regard to use or disclosure of its own Confidential

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Information or Highly Confidential Information.

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4.

Confidential Information and Highly Confidential

Nothing in this Agreement shall restrict a

A Disclosing Party may designate as "Confidential Information" any Discovery

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Material that contains proprietary or9ther confidential information of either its own or of another

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which the Disclosing Party is under a duty to maintain confidential. Confidential Information as

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used in this Agreement shall refer to any so designated material and all copies thereof, and shall

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also refer to the information contained in such materials. No designation shall be made unless

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counsel of record believes in good faith that the designated material is entitled to protection under

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Rule 26 of the Federal Rules of Civil Procedure.

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5.

Except as provided in Paragraph 10, all documents containing Confidential

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Information shall be marked at the time that copies are produced to a Receiving Party with the

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legend "CONFIDENTIAL" stamped or labelled on each page (or on the first page only of a bound

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document) in lettering at least y,; high and in a manner so as not to interfere with the legibility

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thereof. Documents must be so designated at the time of delivery to a Receiving Party pursuant to

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Fed. R. Civ. P. 33(c).

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II

6.

Discovery Material designated as Confidential Information shall be maintained in

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confidence by the Receiving Party pursuant to the requirements of Paragraph 3 herein, and shall

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not be disclosed to any person except:

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a.

the Court and its officers, under seal;

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b.

lead and local outside counsel of record and employees of such counsel of

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record;

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c.

in-house counsel and their support staff;

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d.

officers and employees of the Receiving Party provided that any such officer
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5422315_2.DOCX

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or employee of the Receiving Party has signed a declaration in the fonn of

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Exhibit A hereto (copies of which signed declaration shall be provided to

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the other parties herein upon request); and

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e.

an independent expert or consultant engaged by counselor the parties to

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assist in this litigation who is not a past or current employee or director of a

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party (hereinafter "Expert") provided that such Expert has signed an

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undertaking in the form of Exhibit A hereto (copies of which signed

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declaration shall be provided to the other parties herein only upon a showing

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of good cause).

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7.

A Disclosing Party may designate as "Highly Confidential Information" any

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Discovery Material that contains Confidential Information that constitutes trade secret or other

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proprietary competitive information that the Disclosing Party believes in good faith should not be

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disclosed to non-experts or non-attorneys of the Receiving Party, including, but not limited to,

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confidential financial information or other proprietary business or technical information. Highly

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Confidential Information shall refer to any so designated material and all copies thereof and shall

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also refer to the information contained in such materials. No designation shall be made unless

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counsel of record believes in good faith that the designated material is entitled to protection under

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Rule 26 of the Federal Rules of Civil Procedure and the standard set forth herein.

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8.

Except as provided in Paragraph 10, all documents containing Highly Confidential

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Information shall be marked at the time that copies are produced to a Receiving Party with the

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legend "HIGHLY CONFIDENTIAL ATTORNEYS' EYES ONLY" or the legend "HIGHLY

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CONFIDENTIAL COUNSEL ONLY" stamped or labelled on each page (or on the first page only

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of a bound document) in lettering at least

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legibility thereof. Documents must be so designated at the time of inspection by, or delivery to, a

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Receiving Party pursuant to Fed. R. Civ. P. 33(c).

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9.

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high and in a manner so as not to interfere with the

Discovery Material designated as Highly Confidential Infonnation shall be

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maintained in confidence for use by litigation counsel who must have access to such

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documentation solely for use in connection with this action and shall not be disclosed to any
Page 3 of II

person except:

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a.

the Court and its officers, under seal;

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b.

lead and local outside counsel of record and employees of such counsel of

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record;

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c.

one (1) in house counsel for each party; and

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d.

Experts, provided that each such Expelt(s) has signed an undertaking in the

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form of Exhibit A hereto (copies of which signed declaration shall be

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provided to the other parties herein only upon a showing of good cause).

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10.

When producing files and records for inspection, no marking need be made by the

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Disclosing Party in advance of the inspection. For purposes of the inspection by the Receiving

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Party, all documents produced shall be considered as "Highly Confidential Information."

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Thereafter, upon selection of specified documents for copying by the Receiving Party, or should

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the Disclosing Party copy and produce documents directly without an initial inspection, the

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Disclosing Party shall mark the documents as provided for in Paragraphs 5 and 8.

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The transcript of any deposition or hearing and all exhibits or attachments shall be

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considered Highly Confidential Information for 30 days following the date such transcript is

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available. During that 30-day period, either party may designate the portions of the transcript, and

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any specific exhibits or attachments, that are to be treated as Confidential Information or Highly

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Confidential Information, in accordance with this Protective Order. Appropriate stampings or

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markings should be made during this time. If no such designations are made during the 30-day

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period, then the entire transcript and exhibits will be considered unprotected.

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12.

A party that seeks to disclose to an Expert any Confidential Information or Highly

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Confidential Information must first provide written notification to the Disclosing Party that (1) sets

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forth the full name of the Expert and the city and state of his or her primary residence, (2) attaches

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a copy of the Expert' s current resume Icurriculum vitae, and (3) identifies the Expert's current

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employer(s).

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thereafter disclose to such Expert any such Confidential Information or Highly Confidential

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Infonnation in accordance with this Agreement unless the Disclosing Party, within the seven-day

Seven calendar days after providing such written notification, such party may

Page 4 of 11

period, provides a written objection to the other party including an explanation and grounds for
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such objection. Counsel that receives a timely written objection shall promptly confer in good

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faith, in person or by telephone, with counsel for the Disclosing Party to reconsider the challenged

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designation. If after conferring the parties are unable to reach agreement as to the objection, the

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objection is deemed waived unless the objecting party files a motion for a determination by the

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Court as to the unresolved objections within seven days after the parties first conferred on the

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issue. The objecting party shall have the burden of proving the propriety of the objection.

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13.

Any employee, officer, or Rule 30(b)(6) witness of the Disclosing Party may be

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shown a document designated as Confidential Information or Highly Confidential Infonnation by

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the Disclosing Party for the purpose of interrogation by the Receiving Party at a deposition or

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hearing. Any person who is not a party or officer or employee of a party, but who was the author

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or copy recipient of a document designated as Confidential Information or Highly Confidential

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Information may be shown Confidential Information or Highly Confidential Information for the

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purpose of interrogation of such person at a deposition or hearing.

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pursuant to this Agreement sha1l constitute or be construed as an acknowledgement or admission

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that any Discovery Materials designated by a Disclosing Party as such are in fact Confidential

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Information or Highly Confidential Information or entitled to confidential treatment.

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Agreement shall be without prejudice to either party to question or challenge at any time whether

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or not any particular infonnation is Confidential Information or Highly Confidential Infonnation.

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14.

15.

Nothing in this Agreement nor acceptance by a party of disclosure of information

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Each party agrees that if it designates any Discovery Material as Confidential

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Information or Highly Confidential Infonnation, and the Receiving Party objects in writing that the

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designation is not warranted or justified as to all or any part of the designated material, then within

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14 days of the written objection, the Disclosing Party shall confer in good faith, in person or by

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telephone, with the Receiving Party to reconsider the challenged designation. If after conferring

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the Receiving and Disclosing Parties are unable to reach agreement as to the challenged

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designation, then the objecting party may file a motion for a determination by the Court as to the

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unresolved objections and the appropriateness of the challenged designation. lfthe objecting party
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542231S_2.DOCX

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does not file a motion challenging the designation within 30 days from the date the Receiving and

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Disclosing Parties first confer on the issue (or within 14 days if discovery has closed), and unless

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otherwise ordered by the Court, the challenged designation shall stand. The Disclosing Party shan

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have the burden of proving the propriety of the challenged designation.

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16.

Nothing in this Agreement shall preclude any Receiving Party, or any other person

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who is bound by this Agreement, from utilizing information that was known to or possessed by the

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Receiving Party or other person before the Receiving Party or other person became bound by this

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Agreement, or which lawfully came into the Receiving Party's or other person's possession outside

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of the discovery process in this action. Any such use of such infonnation shall not constitute a

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violation of this Agreement. Nevertheless, each Disclosing Party retains the right to pursue any

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claim or defense it may have against any Receiving Party or other person arising from such use of

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such information. However, if a Disclosing Party disputes the Receiving Party's or other person's

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position, it shall object in writing, and shall proceed as set forth in Paragraph 15 hereto. If the

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Court determines that, consistent with Fed. R. eiv. P. 26(c) and the provisions of this Protective

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Order, the infonnation in question appears to be of a type that should be characterized as

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Confidential Information or Highly Confidential Information, then any Receiving Party or other

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person claiming that the information has been in the possession of such Receiving Party or other

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person or has been in the public domain prior to disclosure of such information through discovery,

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shall have the burden of proving such prior or public knowledge or possession.

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17.

To the extent that any discovery is taken of any person who is not a party to this

21

action ("Third Party"), and in the event such Third Party or any party contends that the discovery

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sought involves confidential material, then such Third Party shall be provided a copy of this

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Protective Order and given the opportunity to designate information as Confidential Information or

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Highly Confidential Information in accordance with the terms of this Protective Order.

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18.

No Confidential Information or Highly Confidential Information designated in this

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action shall be filed in the public record of this action except as provided herein or otherwise

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pursuant to Court Order.

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19.

If Confidential Information or Highly Confidential Information is disclosed to any
Page 6 of 11

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person other than in the manner authorized by this Agreement, the party responsible for the

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disclosure must immediately bring all pertinent facts relating to such disclosure to the attention of

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all counsel of record and, without prejudice to other rights and remedies of the Disclosing Party,

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make every effort to prevent further disclosure by it or by the person who was the recipient of such

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information.

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20.

The inadvertent or unintentional failure to designate discovery materials as

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Confidential Information or Highly Confidential Information shall not be deemed a waiver in

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whole or in part of a Disclosing Party's claim of confidential treatment under the terms of this

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Agreement. If a document, transcript, or thing is produced for which the designation Confidential

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Information or Highly Confidential Information is lacking but should have appeared, the

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Disclosing Party may restrict future disclosure of the document, transcript, or thing in accordance

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with this Agreement by notifying the Receiving Party in writing of the change in or addition of

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such restrictive designation with respect to the document, transcript, or thing, and providing

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substitute copies, with appropriate designations, of each such document, transcript, or thing. The

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Receiving Party shall then take reasonable steps to prevent any further disclosure of such newly

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designated Confidential Information or Highly Confidential Information, except as permitted by

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this Agreement, and shall, within ten (10) business days of receipt of the substitute copies, return

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or destroy the originally produced items and all copies.

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21.

Any person in possession of another party's Confidential Information or Highly

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Confidential Information who receives a subpoena (or other process) from any person (including

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natural persons, corporations, partnership, firms, governmental agencies, departments or bodies,

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boards, or associations) that is not a party to this Agreement seeking production or other disclosure

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of such Confidential Information or Highly Confidential Information shall, if not otherwise

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prohibited by law, give prompt written notice to counsel for the Disclosing Party of such

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infonnation, identifying the material sought and enclosing a copy of the subpoena or other process.

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Where possible, at least ten (10) business days notice before production or other disclosure shall be

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given. In no event shall production or disclosure be made before the latest of: (1) the date on

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which the notice is given, or (2) the return date of the subpoena or other process. The party
Page 7 of 11
5422315JOOCX

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receiving the subpoena (or other process) shall reasonably cooperate with efforts by the Disclosing

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PaIiy to oppose production pursuant to the subpoena or to condition production upon the

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imposition of conditions to protect against public disclosure of Confidential Information and

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Highly Confidential Information. Further, if production pursuant to the subpoena or other process

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is required before reasonable notice can be given to counsel for the Disclosing Party of such

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information, counsel for the party receiving the subpoena shall object in writing to the production

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by stating that the information sought has been designated Confidential Information or Highly

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Confidential Information.
22.

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Nothing herein shall be construed to affect in any way the admissibility of any

Discovery Material affected or designated under this Agreement.

II

23.

Within thirty (30) days of final termination of this action, including any appeals (or

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such other aIllount oftline on which counsel mutually agree), each Receiving Party shall be under

13

obligation to assemble and return to the Disclosing Party, or alternatively, upon mutual agreement

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of the parties and counsel, to destroy and provide a certificate of destruction of, all material

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received, directly or indirectly from the Disclosing Party embodying Confidential Information or

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Highly Confidential Information, including all copies of such material which may have been made.

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The return of such material shall be acknowledged by the Disclosing Party in writing.

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Furthermore, counsel shall destroy all copies with any attorneys' markings, and any digests or

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summaries thereof which have been made, or prepared from such documents in the course of

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creating attorney work product. Notwithstanding the foregoing, to the extent such material is

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incorporated into any attorney work product or document or exhibit properly filed with the COUli,

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a single copy of such material may be retained in outside counsel's files.

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The attorneys for the parties shall make good faith efforts to resolve any dispute

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about the interpretation of andlor the conduct or activities of any party or person under this

25

Protective Order. If a dispute cannot be resolved, then a dissatisfied party may seek relief from or

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clarification or modification or enforcement of this Protective Order by means of a motion to the

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Court.

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25.

The Court shall retain jurisdiction over the pru1ies for purposes of enforcement of
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5422315.J.OOCX

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this Order.

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IT IS SO ORDERED.

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6th
Dated: _ _ dayof

March

, 2012.

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5
UNITED STATES DISTRICT
GEORGE FOLEY, JR.
COURT JUDGE
United States Magistrate Judge

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APPROVED FOR ENTRY:

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CYBERGUN S.A. and FN HERSTAL, S.A.

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By:

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Dated: rVt. ti\;-yC '" ..s ( ;:}-OI ~
Brett L. Foster
Richard T. Jackson
HOLLAND & HART LLP
222 S. Main Street, Suite 2200
Salt Lake City, UT 84101
J. Stephen Peek, Esq.
Michael W. Wadley, Esq.
HOLLAND & HART LLP
9555 Hillwood Drive, 2nd Floor
Las Vegas, NV 89134

Thomas I. Rozsa
ROZSA LAW GROUP LC
18757 Burbank Blvd., Suite 220
Tarzana, CA 91356-3346

Attorneys for Defendant
Jag Precision

Attorneysfor Plaintiffs
Cybergun S.A. and FN Herstal, S.A.

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Page 9 of 11
5422315JDOCX

1

EXHIBIT A

2

UNITED STATES DISTRICT COURT

3

DISTRICT OF NEV ADA

4 CYBERGUN S.A., a French Corporation, and
FN HERSTAL, S.A., a Belgian Corporation,
5
Plaintiffs,
6
v.
7
JAG PRECISION, a California Corporation,
8
Defendant.
9

CASE NO. 2:12-cv-00074-KJD-GWF
DECLARATION OF
_ _ _ _ _ __ __ RE:
PROTECTIVE ORDER WITH
RESPECT TO CONFIDENTIAL
INFORMATION AND DOCUMENTS

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I, _ _ _ _ __ _ _ _ _ _ _ _ _-', declare that:

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1.

My address is _ _ _ _ __ _ _ _ _ _ _ _ __

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2.

My present employer is _ _ _ _ _ _ _ _ _ and the address of my present

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_ _ __

employmentis _ _ _ _ _ _ __ __ _ _ _ _ _ _ _ _ ___
3.

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I have read and know the contents of the Stipulated Protective Order that the Court

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entered on ______ _, 2012.
4.

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I am one of the persons described in the Order, and I am executing this Declaration

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and agreeing to be bound by its terms in order to satisfy the conditions provided in the Order prior

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to the disclosure to me of any confidential information under the Order.

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5.

I have read and I shall be fully bound by the terms of the aforesaid Order.

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6.

All such documents and information which are disclosed to me pursuant to the

21

Order shall be maintained by me in strict confidence and I shall not disclose or use the original or

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any copy of, or the subject of, such documents and/or information except in accordance with the

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aforesaid Order.

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7.

I shall not use or refer to any of the aforesaid documents and/or information, or

25

copies thereof, other than in connection with the above-entitled action and as provided in the

26

Order.

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8.

I shall, upon being notified of the termination of the above-entitled action, return all

copies of such documents to counsel from whom I receive such documents, and I shall destroy any
Page 10 of 11
5422315 _1.DOCX

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notes and/or memoranda r have regarding the aforesaid documents and/or infonnation.

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9.

J do and shall subject myself to the continuing jurisdiction of the United States

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District Court for the Central District of California over my person, wherever

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enforcement of the aforesaid Order.

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foregoing is true and correct.

Date:

---------------------

[SIGNATURE]

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be, for the

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Page 11 ofl1
5422315 JDOCX