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Strojnik v. Block 22 LLC

United States District Court, D. Idaho

December 12, 2019

PETER STROJNIK, Plaintiff,
v.
BLOCK 22 LLC dba THE GROVE HOTEL, Defendant.

          PROTECTIVE ORDER

          B. Lynn Winmill U.S. District Court Judge

         Pursuant to Rules 26 and 29 of the Federal Rules of Civil Procedure, the Court's Memorandum Decision and Order (Dkt. 20) and the parties' Stipulation for Protective Order hereby:

         1. That this Protective Order governs the production, use, and dissemination of information and documents that are produced by Defendant Block 22 LLC doing business as The Grove Hotel, (“Defendant”).

         2. Designation and Provision of Protected Material. Defendant may designate as “CONFIDENTIAL” any document, or portion thereof, which it reasonably believes it must produce pursuant to the Court's Memorandum Decision and Order (Dkt. 20) including confidential, privileged, proprietary, private and/or other sensitive information such as, but not limited to, non-public personal, financial, corporate and business records and data. All such documents shall be subject to the terms and conditions set forth in this Protective Order and shall be referred to herein as the “Protected Material.”

         The designation of all or a portion of a document as “CONFIDENTIAL” shall be made by placing such legend on each designated page of the document prior to production of the document. In no event shall said mark or stamp interfere with the legibility of any part of a document.

         3. Access to and Use of Protected Material. Protected Material shall not be used for purposes other than for the litigation of this case, defined as Peter Strojnik v. Block 22 LLC doing business as The Grove Hotel, No. 1:18-cv-00556-BLW, U.S. District Court, District of Idaho, and any related appellate proceedings, and shall not be disclosed to any person or entity other than:

a. Plaintiff, his attorneys[1], agents, employees and representatives who have a need to know or to have access to the information, and their respective legal counsel and such counsel's legal associates, paralegals, secretaries, and office staff;
b. Plaintiff's independent experts or consultants specifically retained by Plaintiff to assist counsel in this litigation and the experts' or consultants' respective office staff;
c. Defendant, its attorneys, agents, employees and representatives who have a need to know or to have access to the information, and their respective legal counsel and such counsel's legal associates, paralegals, secretaries, and office staff;
d. Defendant's independent experts or consultants specifically retained by Defendant to assist counsel in this litigation and the experts' or consultants' respective office staff;
e. The Court, court reporters, courtroom personnel, jurors, and witnesses testifying at trial;
f. Such other person(s) as the Court shall determine.

         4. Disclosure to Experts or Consultants. Any independent expert or consultant retained to assist Plaintiff or Plaintiff's counsel in this litigation shall, prior to any disclosure to the expert or consultant of the Protected Material, execute an agreement to be bound by the Protective Order (the “Confidentiality Agreement”)[2]. A copy of the Confidentiality Agreement is attached hereto as Exhibit “A”. A copy of the signed Confidentiality Agreement shall be provided to opposing counsel prior to any disclosure.

         5. Copies of Protected Material. Copies of Protected Material may be made by or for only those persons identified in Paragraph 3 as authorized recipients of Protected Material, provided that all copies and extracts are appropriately marked as “CONFIDENTIAL.” All copies of Protected Material ...


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