Case 2:14-cv-00167-JCM-CWH Document 75 Filed 02/06/15 Page 1 of 12Case 2:14-cv-00167-JCM-CWH Document 76 Filed 02/09/15 Page 1 of 12
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`
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`S. BRENT VOGEL
`Nevada Bar No. 6858
`ALAYNE M. OPIE
`Nevada Bar No. 12623
`LEWIS BRISBOIS BISGAARD & SMITH LLP
`6385 S. Rainbow Boulevard, Suite 600
`Las Vegas, Nevada 89118
`702.893.3383
`FAX: 702.893.3789
`brent.vogel@lewisbrisbois.com
`alayne.opie@lewisbrisbois.com
`Attorneys for Defendant Narconon Fresh
`Start dba Rainbow Canyon Retreat (“Fresh Start”)
`
`
`
`UNITED STATES DISTRICT COURT
`
`FOR THE DISTRICT OF NEVADA
`
`
`
`DAVID WELCH, a Texas Citizen; STACY
`WELCH, a Texas Citizen; and JACK WELCH,
`a Texas Citizen,
`
`
`Plaintiffs,
`
`CASE NO. 2:14-cv-00167-JCM-CWH
`Dept. No.: 3
`
`STIPULATED PROTECTIVE ORDER
`
`
`
`IT IS HEREBY STIPULATED AND AGREED by and between the undersigned counsel
`
`as follows:
`
`1.0
`
`GENERAL INFORMATION:
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`
`
`1.1
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`Definitions - As used in this Order, the word:
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`1.1.1
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`“Party” or “Parties” shall include Plaintiffs DAVID WELCH, STACY
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`WELCH, JACK WELCH, and Defendants NARCONON FRESH START dba
`
`4827-4747-6769.1
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`
`
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`
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`
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`NARCONON FRESH START d/b/a
`RAINBOW CANYON RETREAT, a
`California Corporation; ASSOCIATION FOR
`BETTER LIVING AND EDUCATION
`INTERNATIONAL; NARCONON
`INTERNATIONAL
`and DOES 1-100, ROE Corporations I-X,
`inclusive,
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`vs.
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`Defendants.
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`LEWIS
`BRISBO
`IS
`BISGAARD
`& SMITH LLP
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`RAINBOW CANYON RETREAT, NARCONON INTERNATIONAL,
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`ASSOCIATION FOR BETTER LIVING AND EDUCATION
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`INTERNATIONAL, and each of their/its/his/her employees, agents,
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`representatives, and attorneys (including both outside counsel and inside
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`counsel).
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`1.1.2
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`“Person(s)” shall include any “Party” to this action, whether an individual,
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`corporation, partnership, company, unincorporated association, governmental
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`agency, or other business or governmental agency.
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`1.1.3. “Confidential Material” shall mean any and all confidential or proprietary
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`documents, data, or information provided in response to written discovery
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`requests, subpoena, deposition testimony, or otherwise produced. All
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`Confidential Materials shall be Bates stamped and marked as confidential with
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`a watermark or legend.
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`1.1.4. “Discovering Party” shall mean the Party who has requested documents
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`designated as Confidential Material under this Stipulated Protective Order or is
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`in possession of documents designated as Confidential Material.
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`1.1.5
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`“Producing Party” shall mean the Party who has produced documents
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`designated as Confidential Material under this Stipulated Protective Order.
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`1.1.6
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`“Fresh Start” shall mean Narconon Fresh Start dba Rainbow Canyon Retreat.
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`1.1.7
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`“NI” shal mean Narconon International.
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`1.1.8
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`“ABLE” shall mean Association For Better Living And Education
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`International.
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`1.1.9
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`“Defendants” shall mean Narconon Fresh Start dba Rainbow Canyon Retreat,
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`Narconon International and Association For Better Living And Education
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`International.
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`1.1.10 “Licensing Agreement” shall mean the License Agreement dated May 14,
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`2001, by and between Narconon International and Narconon Southern
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`4827-4747-6769.1
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`BRISBO
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`California, Inc. previously disclosed and identified as LICENSE-00001-9.
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`1.2
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`Trade Secrets and Proprietary Information:
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`
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`Defendants contend that documents designated as Confidential Material represent
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`and/or reflect trade secrets or other confidential and proprietary research,
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`development or commercial information. The Parties agree Defendants have a
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`legitimate interest in protecting trade secrets, or other confidential and proprietary
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`research, development or commercial information, including those which Fresh Start
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`has been granted the non-exclusive right and license to use pursuant to the Licensing
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`Agreement. The Parties agree the protections within this agreement are adequate.
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`1.3. Nature of this Stipulated Protective Order:
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`
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`The nature of this Stipulated Protective Order is to protect the Parties’ confidential
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`information, including, Defendants’ business interests in their own intellectual
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`property, information, and processes. Furthermore, the nature of this Stipulated
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`Protective Order is protect Fresh Start from any liabilities that arise out of the
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`Licensing Agreement. Defendants contend that disclosure of their trade secrets,
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`confidential or proprietary information or any of those referenced in the Licensing
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`Agreement, could cause irreparable and significant harm to Fresh Start, Narconon
`
`International, Association For Better Living And Education, and their affiliates. This
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`Stipulated Protective Order is intended to prevent this foreseeable harm and any
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`related unforeseeable harm.
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`1.4
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`Public Health & Safety Not At Issue:
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`
`
`The documents and information at issue do not involve the public health and safety, a
`
`public entity, or issues important to the general public.
`
`1.5
`
`Good Faith Discovery Cooperation:
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`
`
`It is the purpose of this Stipulated Protective Order and the desire of the Parties to
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`make the broadest range of reasonably relevant documents available to the Parties,
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`without waiving any trade secrets, privilege, or otherwise proprietary information,
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`4827-4747-6769.1
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`BRISBO
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`BISGAARD
`& SMITH LLP
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`while protecting all Parties interests’, while adhering to the Licensing Agreement, and
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`without subjecting the Parties and the Court to numerous discovery motions.
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`1.6
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`Reliance on this Agreement:
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`
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`The Parties agree to limit dissemination of any documents and information as set forth
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`in this Stipulated Protective Order and are materially relying on the representations
`
`and covenants contained within.
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`2.0
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`SCOPE, RELIANCE AND PURPOSE:
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`2.1
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`It is a purpose of this Stipulated Protective Order that Defendants will be provided
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`reasonable assurance that:
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`2.1.1 The documents or information produced by Defendants will be used
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`in this litigation and this litigation only and similar litigation involving
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`the same Defendants and counsel only;
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`2.1.2 The documents or information produced by Defendants will not be
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`used for commercial purposes;
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`2.1.3 The documents or information produced by Defendants will not be
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`used for non-litigation purposes.
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`2.2
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`The Parties are relying on this Stipulated Protective Order, and would not have
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`produced the documents and information otherwise.
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`2.3
`
`The Parties’ production under this Stipulated Protective Order does not admit or
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`concede the documents or information are relevant or admissible in this litigation.
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`This Stipulated Protective Order survives the end of the above-styled litigation.
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`The Parties agree good cause exists for this Stipulated Protective Order and for the
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`2.4
`
`2.5
`
`Court to enter this Order.
`
`2.6
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`Compliance with this Stipulated Protective Order will be a material term to any
`
`settlement agreement reached in this case.
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`3.0
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`PRODUCTION OF DOCUMENTS:
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`3.1
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`Any documents produced, produced for inspection and/or made available for copying
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`4
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`LEWIS
`BRISBO
`IS
`BISGAARD
`& SMITH LLP
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`in this action by any Party to this litigation or any third parties whether before or after
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`the date of entry of this Order may be designated Confidential Material. Such a
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`designation shall be made by placing a watermark or legend inscribing the word
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`“Confidential” on the face of each page of each document so designated. In the event
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`a book is produced, the material shall be designated as Confidential Material by placing
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`a watermark or legend inscribing the word “Confidential” on the front cover of the
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`book. Thereafter, if any single page from the book is duplicated, the individual pages
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`shall be designated Confidential Material by placing a watermark or legend inscribing
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`the word “Confidential” on each page of the document so designated.
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`3.2
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`Such Confidential Materials in whole or in part or in any form, and the information
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`within, may be used and disclosed solely for the preparation and trial of this litigation
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`only, including all appeals. Copies of any discovery designated “Confidential” shall
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`only be provided to parties or persons as identified within this Stipulated Protective
`
`Order.
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`3.3
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`The Parties and their counsel agree to use reasonable efforts not to disclose the
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`information to any third person or entity whatsoever, except to (the following are
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`collectively referred to as “Qualified Person(s)”):
`
`a.
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`b.
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`counsel of record in this action on behalf of a Party to this litigation;
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`employees or agents of counsel including regularly employed support
`
`staff, paralegal and clerical personnel who have a direct responsibility
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`for assisting such counsel in the preparation and trial of litigation,
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`including appeals;
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`c.
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`outside consultants and experts and their employees or agents retained
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`by counsel or any Party to this litigation for the purpose of assisting in
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`the preparation and trial of this litigation, including appeals;
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`d.
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`the United States District Court, District of Nevada, (“the Court”), and
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`court personnel, including stenographic reporters regularly employed
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`4827-4747-6769.1
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`by the Court;
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`e.
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`f.
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`stenographic or video reporters who are otherwise engaged in such
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`proceedings as are necessarily incident to the conduct of this litigation;
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`witnesses or prospective witnesses requested by counsel to give
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`testimony or otherwise to prepare for any deposition, hearing, trial or
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`other proceeding in this litigation.
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`Any person or group of people who do not each meet the criteria of a
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`Qualified Person as defined above, shall be deemed to be a “non-qualified
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`person” or “non-qualified persons.”
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`4.0 DEPOSITIONS
`
`
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`Deposition testimony concerning any Confidential Material shall be designated as Confidential
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`Material under the terms of this Stipulated Protective Order. The court reporter shall note on the
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`record the designation of Confidential Material and shall separately transcribe those portions of the
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`testimony so designated and shall mark the face of such portion of the transcript as “Confidential
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`Material.” The Parties may use Confidential Material during any deposition provided the witness is
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`apprised of the terms of this Stipulated Protective Order and executes the AGREEMENT TO BE
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`BOUND BY PROTECTIVE ORDER REGARDING CONFIDENTIAL INFORMATION,
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`attached as Exhibit “A.” The Parties may use Confidential Material during a deposition only if the
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`room is first cleared of all non-qualified persons.
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`5.0
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`CONTESTING THE DESIGNATION OF CONFIDENTIAL MATERIAL
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`
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`In the event that any Party desires to contest the designation of any documents, information,
`
`or testimony as Confidential Material, that Party shall, after requesting and being denied re-
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`designation within a timely manner, shall file an objection with the Court and request a hearing on the
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`matter. At such hearing, the Party designating the information as Confidential Material shall have the
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`burden to establish that Party’s right to protection of the Confidential Material. All such documents,
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`information or testimony shall be treated as Confidential Material until the Court makes a decision
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`regarding the status of the documents, information and testimony.
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`4827-4747-6769.1
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`7.0
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`VIEWING OF DOCUMENTS BY THIRD PARTIES:
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`
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`The Parties agree and acknowledge that before disclosing any Confidential Material to a
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`Qualified Person, as defined above in Section 3.3(c) of this Stipulated Protective Order, the Party shall
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`provide to the Qualified Person a copy of this Stipulated Protective Order and each Qualified Person
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`shall execute a copy of the attached AGREEMENT TO BE BOUND BY PROTECTIVE ORDER
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`REGARDING CONFIDENTIAL INFORMATION. The executed copy of Exhibit “A” shall be
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`retained by the attorney who has disclosed the Confidential Material to the Qualified Person.
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`8.0 NO WAIVER BY INADVERTENT PRODUCTION:
`
`
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`If any Confidential Material is inadvertently provided to a Discovering Party without being
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`marked as Confidential in accordance with this Order, the failure to so mark the material shall not be
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`deemed a waiver of its confidentiality, privilege, or right to object.
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`9.0
`
`RETURN OF DOCUMENTS AT END OF LITIGATION:
`
`
`
`Within ten (10) days after the final settlement or termination of action, it is the obligation of
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`the Discovering Party to return or destroy all Confidential Material provided by the Producing Party.
`
`The Discovering Party shall return or destroy all Confidential Material, including all copies, notes,
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`tapes, papers and any other medium containing, summarizing, excerpting, or otherwise embodying
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`any Confidential Material, except that the Discovering Party shall be entitled to destroy, rather than
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`return (a) any Confidential Material stored in or by data processing equipment and (b) work product
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`memoranda or pleadings embodying Confidential Material, subject to State Bar rules. The Discovering
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`Party will confirm in writing to the Producing Party its compliance with this Section 9.0.
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`10.0 PHOTOCOPYING PROHIBITED BEYOND THIS LITIGATION:
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`
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`The Confidential Material shall not be photographed, photocopied or reproduced in any
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`manner except in preparation of or otherwise related to this litigation.
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`11.0 PUBLICATION PROHIBITED:
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`
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`The Confidential Material shall not be published or reproduced in any manner on the Internet,
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`blogs, bulletin boards, email, newspapers, magazines, bulletins, or other media available publicly or
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`privately. Likewise, persons may not verbally share the Confidential Material to non-qualified
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`LEWIS
`BRISBO
`IS
`BISGAARD
`& SMITH LLP
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`persons.
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`12.0 ALL DOCUMENTS REVEALED TO THE COURT SHALL BE SEALED:
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`
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`All motions or other documents filed with the Court, if any, which reveal, include, attach or
`
`make reference to any portion of the Confidential Material shall be filed in accordance with the
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`Federal Rules of Civil Procedure and shall be considered Confidential Material governed by the terms
`
`of this Stipulated Protective Order.
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`13.0 NON-WAIVER:
`
`
`
`This Stipulated Protective Order is not, and shall not be interpreted as, a waiver by any Party
`
`of any right to claim in this lawsuit or otherwise, that the documents or information are privileged or
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`otherwise undiscoverable.
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`14.0 VIOLATION OF ORDER:
`
`
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`Upon an alleged violation of this Stipulated Protective Order, the Court on its own motion or
`
`on the motion of any Party may grant relief as it deems appropriate in law or equity. Should any
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`provision of this Stipulated Protective Order be struck or held invalid by a court of competent
`
`jurisdiction, all remaining provisions shall remain in full force and effect.
`
`
`
`
`
`Dated this 6th day of February, 2015.
`
`
`
`
`
`/s/ Artumus Ham
`By:
`Ryan Hamilton, Esq.
`HAMILTON LAW
`5125 S. Durango Drive, Suite C
`Las Vegas, Nevada 89113
`and
`Artumus Ham, Esq.
`EGLET LAW GROUP
`400 S. 7th Street, 4th Floor
`Las Vegas, Nevada 89101
`Attorneys for Plaintiffs
`
`Dated this 6th day of February, 2015.
`
`LEWIS BRISBOIS BISGAARD & SMITH LLP
`
`
`
`
`
`
`
`
`/s/ Alayne Opie
`By:
`
`
`
`S. Brent Vogel
`
`
`
`
`Nevada Bar No. 006858
`
`
`
`Alayne M. Opie
`
`
`
`
`Nevada Bar No. 12623
`
`6385 S. Rainbow Boulevard, Suite 600
`
`Las Vegas, Nevada 89118
`
`
`
`Attorneys for Defendant Narconon Fresh
`
`Start dba Rainbow Canyon Retreat (“Fresh Start”)
`
`
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`. . .
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`. . .
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`. . .
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`BRISBO
`IS
`BISGAARD
`& SMITH LLP
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`

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`Dated this 6th day of February, 2015
`
`BAKER, KEENER & NAHRA, LLP
`
`/s/ Robert Baker
`By:
`Robert C. Baker
`Baker, Keener & Nahra, LLP
`633 West 5th Street, Suite 5500
`Los Angeles, California 90071
`and
`Robert McBride
`CARROLL, KELLY, TROTTER, FRANZEN, MCKENNA & PEABODY
`701 North Green Valley Pkwy, Suite 200
`Henderson, Nevada 89074
`Attorney for Narconon International
`and Association For Better Living
`And Education International
`
`
`
`ORDER
`
`
`
`
`
`Based upon the foregoing Stipulation, and good cause appearing therefore,
`
`IT IS HEREBY ORDERED that the Parties have entered into a STIPULATED
`
`PROTECTIVE ORDER governing production of documents.
`
`
`
`IT IS FURTHER ORDERED that the Parties shall be bound by the Stipulated Protective
`
`Order.
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`Respectfully submitted by:
`
`
`
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`
`
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`United States District Court Judge
`
`
`
`
`
`
`
`LEWIS BRISBOIS BISGAARD & SMITH LLP
`
`
`
`
`
`
`
`
`
`
`
`
`
`/s/ Alayne Opie
`By:
`S. Brent Vogel, NV Bar 6858
`Alayne M. Opie, NV Bar 12623
`6385 S. Rainbow Boulevard, Suite 600
`Las Vegas, Nevada 89118
`Attorneys for Defendant Narconon Fresh
`Start dba Rainbow Canyon Retreat (“Fresh Start”)
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`4827-4747-6769.1
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`LEWIS
`BRISBO
`IS
`BISGAARD
`& SMITH LLP
`
`United States Magistrate Judge
`
`DATED: February 9, 2015
`
`

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`EXHIBIT “A’
`
`UNITED STATES DISTRICT COURT
`
`DISTRICT OF NEVADA
`
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`DAVID WELCH, a Texas Citizen; STACY
`WELCH, a Texas Citizen; and JACK WELCH,
`a Texas Citizen,
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`Plaintiffs,
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`CASE NO. 2:14-cv-00167-JCM-CWH
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`Dept. No.: 3
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`AGREEMENT TO BE BOUND BY PROTECTIVE ORDERREGARDING
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`CONFIDENTIAL INFORMATION
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`I hereby attest to my understanding that information or documents designated as Confidential
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`Material and the information contained therein are provided to me pursuant to the terms and
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`conditions and restrictions of the STIPULATED PROTECTIVE ORDER entered in the above-
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`styled case. I have been given a copy, read, and understand the STIPULATED PROTECTIVE
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`ORDER. I agree to be bound by it, and consent to the personal jurisdiction of the Court that signed
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`the STIPULATED PROTECTIVE ORDER, for enforcement.
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`I further agree that I shall not disclose to others in any manner, except in accordance with the
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`STIPULATED PROTECTIVE ORDER, any Confidential Material as defined in that agreement, and
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`that such Confidential Material shall be used only for the purposes of the captioned legal proceeding.
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`I understand that the unauthorized disclosure of Confidential Material could result in the violation of
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`the rights to privacy, and/or serious economic harm to the party providing the Confidential Material
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`4827-4747-6769.1
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`NARCONON FRESH START d/b/a
`RAINBOW CANYON RETREAT, a
`California Corporation; ASSOCIATION FOR
`BETTER LIVING AND EDUCATION
`INTERNATIONAL; NARCONON
`INTERNATIONAL
`and DOES 1-100, ROE Corporations I-X,
`inclusive,
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`LEWIS
`BRISBO
`IS
`BISGAARD
`& SMITH LLP
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`Case 2:14-cv-00167-JCM-CWH Document 75 Filed 02/06/15 Page 11 of 12Case 2:14-cv-00167-JCM-CWH Document 76 Filed 02/09/15 Page 11 of 12
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`which could continue to cause harm even after the termination of that legal proceeding. I further
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`agree and attest to my understanding that, in the event that I fail to abide by the terms of that
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`STIPULATED PROTECTIVE ORDER, I may be subject to sanctions, including sanctions by way
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`of contempt of court, imposed by the Court for such failure.
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`___________________________________
`Signature
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`LEWIS
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`Case 2:14-cv-00167-JCM-CWH Document 75 Filed 02/06/15 Page 12 of 12Case 2:14-cv-00167-JCM-CWH Document 76 Filed 02/09/15 Page 12 of 12
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`CERTIFICATE OF SERVICE
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`Pursuant to FRCP 5(b), I certify that I am an employee of Lewis Brisbois Bisgaard & Smith
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`LLP and that on this 6th day of February 2015, I did cause a true copy of STIPULATED
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`PROTECTIVE ORDER to be placed in the United States Mail, with first class postage prepaid
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`thereon, and addressed as follows:
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`William Forman
`SCHEPER KIM HARRIS LLP
`601 W. Fifth Street, 12th Floor
`Los Angeles, California 90071
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`Ryan Hamilton
`HAMILTON LAW
`5125 S. Durango Drive, Suite C
`Las Vegas, Nevada 89113
`Attorney for Plaintiffs
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`Atumus Ham, Esq.
`EGLET LAW GROUP
`400 S. 7th Street, 4th Floor
`Las Vegas, Nevada 89101
`Attorneys for Plaintiffs
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`Bob Baker
`Baker, Keener & Nahra, LLP
`633 West 5th Street, Suite 5500
`Los Angeles, California 90071
`Attorney for Narconon International
`and Association for Better Living
`and Education International
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`Robert McBride
`CARROLL, KELLY, TROTTER, FRANZEN, MCKENNA & PEABODY
`701 North Green Valley Pkwy, Suite 200
`Henderson, Nevada 89074
`Attorney for Narconon International
`and Association for Better Living
`and Education International
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`/s/ Erin Adams
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`An Employee of Lewis Brisbois Bisgaard & Smith LLP
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