STC.UNM v. Intel Corporation

Filing 61

Unopposed MOTION for Protective Order by Intel Corporation. (Attachments: # 1 Exhibit A part 1, # 2 Exhibit A part 2)(Atkinson, Clifford)

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STC.UNM v. Intel Corporation Doc. 61 UNITED STATES DISTRICT COURT DISTRICT OF NEW MEXICO STC.UNM, Plaintiff, v. INTEL CORPORATION, Defendant. UNOPPOSED JOINT MOTION FOR ENTRY OF STIPULATED INTERIM PROTECTIVE ORDER The parties hereby respectfully request that the Court enter of record the attached proposed Stipulated Interim Protective Order to protect confidential, trade secret and other nonpublic information and materials that may be made available in the course of discovery in this case, and whose public disclosure would create a substantial risk of competitive harm to the parties. Pursuant to D.N.M. LR-Civ.7.1(a) this Motion is jointly made on behalf of all parties to this litigation and is unopposed. The parties have met and conferred at length about the terms and provisions that should and should not be included in a protective order. As a result of those discussions, the parties have reached agreement on most but not all of those provisions. To avoid delay in the conduct of discovery, the parties have prepared the proposed Stipulated Interim Protective Order attached as Exhibit A and now request that it be entered pending final resolution of the two issues on which the Parties have yet to reach agreement. Those two issues and the manner in which the parties will present them to the Court for resolution are noted in sections 9(f) and 10(b) of the Stipulated Interim Protective Order. The parties further agree that the terms of the proposed Stipulated Interim Protective Order shall not prejudice either party CV-2010-1077 RB/WDS with regard to the parties' respective positions on the remaining unresolved issues. Finally, the parties agree that the entry of the proposed Stipulated Interim Protective Order is without prejudice to the right of any party to move the Court pursuant to Fed. R. Civ. P. 26(c) and D.N.M. L.Rs.-Civ. 7.1 and 26.5 for supplementation or amendment of the proposed Stipulated Interim Protective Order or the subsequently-entered Protective Order that resolves the outstanding unresolved issues. Concurrently with this Motion, pursuant to D.N.M. LR-Civ.7.2 the parties are submitting to the Court the proposed Stipulated Interim Protective Order in rich text format (.rtf) to In the event the proposed Stipulated Interim Protective Order meets the Court's satisfaction, the parties respectfully request that the Court immediately enter it of record so that the parties may begin their initial productions and exchange of documents. WHEREFORE, for the reasons set forth above, the parties respectfully request that the Court enter the Stipulated Interim Protective Order hereto attached as Exhibit A and simultaneously electronically submitted to the Court in accordance with the local rules. Respectfully submitted, ATKINSON, THAL & BAKER, P.C. /s/ Clifford K. Atkinson Clifford K. Atkinson Douglas A. Baker Justin D. Rodriguez 201 Third St. NW, Suite 1850 Albuquerque, New Mexico 87102 (505) 764-8111 Robert A. Van nest Brian L. Ferrall KEKER & VAN NEST LLP 2 Chad S. Campbell Jonathan M. James Timothy J. Franks Mark E. Strickland Jonathan L. McFarland PERKINS COIE LLP Attorneys for Defendant Intel Corporation -AND/s/ Steven R. Pedersen Deron B. Knoner, Esq. KELEHER & MCLEOD, P.A. PO Box AA Albuquerque, NM 87103 (505) 842-9150 George C. Summerfield, Esq. Joseph A. Grear, Esq. Keith A. Vogt, Esq. Rolf O. Stadheim, Esq. Steven R. Pedersen, Esq. STADHEIM & GREAR, LTD. Attorneys for Plaintiff STC.UNM CERTIFICATE OF SERVICE The undersigned certifies that on the 30th day of March, 2011 the foregoing was filed electronically through the CM/ECF system, which caused all parties or counsel to be served by electronic means. /s/ Justin D. Rodriguez Justin D. Rodriguez 3

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