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Prestige Flag Mfg. Co., Inc. v. Golf Solutions I, LLC

United States District Court, W.D. Wisconsin

May 23, 2018

PRESTIGE FLAG MFG. CO., INC., a California corporation, Plaintiff,
v.
GOLF SOLUTIONS 1, LLC, Wisconsin limited liability company doing business as Laser Link Golf, Defendant.

          Bradley C. Graveline Counsel for Prestige Flag Mfg. Co., Inc.

          Maxwell J. Petersen Counsel for Golf Solutions I, LLC

          JURY TRIAL DEMANDED

         PROTECTIVE ORDER

         Plaintiff Prestige Flag Mfg. Co., Inc. ("Prestige") and Defendant Golf Solutions I, LLC ("Golf Solutions") (collectively, "the Parties"), have agreed to the terms in this Joint Proposed Protective Order. The Parties have moved that the Court enter this Protective Order. The Court has determined that the terms set forth herein are appropriate to protect the respective interests of the Parties, the public, and the Court. Accordingly, it is ORDERED:

         I. Scope

         All materials produced or adduced in the course of discovery, including initial disclosures, responses to discovery requests, deposition testimony and exhibits, and information derived directly therefrom (collectively, "Documents"), shall be subject to this Order concerning Protected Information, as defined below. This Order is subject to the Local Rules of this District and the Federal Rules of Civil Procedure on matters of procedure and calculation of time periods.

         II. Definitions

         A. Discovery Material

         As used in this Order, the term "Discovery Material" includes all information contained in at least Documents, things, computer data and reports, deposition testimony and exhibits, interrogatory answers, responses to requests for admission, pleadings, motions, briefs, letters between parties, briefs, affidavits, stipulations, and any other written, recorded, computerized electronic, transcribed or graphic matter produced or provided by any party or non-party or obtained by any party during discovery or in connection with Rule 26(a) disclosures in this action, and any copies, digests, and complete or partial summaries thereof. The terms "Document" or "Documents" shall have the same meaning as used in the Federal Rules of Civil Procedure, including, but not limited to, records, exhibits, reports, samples, transcripts, video or audio recordings, computer files, disks, affidavits, briefs, pleadings, summaries, notes, abstracts, drawings, company records and reports, answers to interrogatories, responses to requests for admissions or document requests, and motions, including copies or computer-stored versions of any of the foregoing, as well as anything meeting the definition of a "writing" as used in Fed.R.Evid. 1001.

         B. Protected Information

         As used in this Order, "Protected Information" means any Discovery Material that the Disclosing Party in good faith designates as "CONFIDENTIAL" or "CONFIDENTIAL -ATTORNEYS' EYES ONLY, " or pursuant to this Order, and any excerpts of such information included in other Documents.

         C. Producing Party

         As used in this Order, "Producing Party" mean any party or third party who provides and/or designates Discovery Material.

         D. Receiving Party

         As used in this Order, "Receiving Party" means any party who receives Discovery Material from a Producing Party.

         E. Outside Counsel

         As used in this Order, "Outside Counsel" means persons who appear on the pleadings as counsel for a Producing Party or Receiving Party in this litigation, as well as the partners, associates, and staff (including, but not limited to, technical advisors) of such counsel to whom it is reasonably necessary to disclose such information for this litigation.

         F. "CONFIDENTIAL"

         As used in this Order, the designation "CONFIDENTIAL" means and applies to: information, Documents, and things concerning a Party's business operations, processes and technical and development information, the disclosure of which is likely to harm that Party's competitive position or which would contravene an obligation of confidentiality to a third person or to a Court, that the Producing Party, (a) would not normally reveal to third parties except in confidence, or has undertaken with others to maintain in confidence, or (b) believes in good faith is protected by a right to privacy under federal or state law, or any other applicable privilege or right related to confidentiality or privacy. Such information or Documents shall be shielded from public access and used only for purposes of this litigation.

         G. "CONFIDENTIAL - ATTORNEYS' EYES ONLY"

         As used in this Order, the designation "CONFIDENTIAL - ATTORNEYS' EYES ONLY" means and applies to information or material that qualifies as "CONFIDENTIAL" that contains current or future trade secrets, financial or business information, and/or other information that is more sensitive and strategic than CONFIDENTIAL information. The information so designated shall only include information that (i) is not in the public domain; (ii)

         has been held in confidence by the Producing Party; (iii) has significant competitive value such that unrestricted disclosure to others would create a substantial risk of significant competitive injury; (iv) the Producing Party believes in good faith is significantly sensitive and protected by a right to privacy under federal or state law; (v) includes data derived from such information or material, including any summaries, compilations, quotes, or paraphrases; and/or (vi) contains information, including identifying information, relating to third party customers/dealers/vendors of a Party. Such information shall be shielded from public access and access by the Parties, and used only for purposes of this litigation.

         III. Time and Manner of Designation

         A. Time of Designation

         Except as otherwise provided in Paragraph IV(D) below, designation of Discovery Material as Protected under Paragraphs 11(F) or (G) shall be made at the following times:

(1) For Documents and things, prior to or at the time of the production of the Document;
(2) For declarations, written discovery responses, and pleadings, at the time of the service or filing, whichever occurs first;
(3) For any form of testimony, either (i) at the time that such testimony is given, or (ii) within thirty (30) calendar days after the receipt of the transcript of such testimony by the Producing Party. Until the expiration of thirty (30) calendar days after receipt of the transcript of such testimony by the Producing Party, all testimony will be treated as "CONFIDENTIAL -ATTORNEYS' EYES ONLY." If no further designation is made, the testimony will remain so designated.

         B. Manner of Designation

         Designation of Discovery Material shall be made by placing the notation "CONFIDENTIAL" or "CONFIDENTIAL - ATTORNEYS' EYES ONLY, " in the following manner:

(1) For Documents, on each page of such document;
(2) For tangible items, on the object or container thereof; or, if not practicable, as otherwise agreed by the Parties;
(3) For declarations, written discovery responses, court filing or pleadings, on the face of such document and ...

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