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Nuvasive, Inc. v. A2 Medical, Inc.

United States District Court, D. Massachusetts

June 2, 2017

NUVASIVE, INC., and THERMAL SURGICAL, LLC, Plaintiffs,
v.
A2 MEDICAL, INC., Defendant.

          NUVASIVE, INC. and THERMAL SURGICAL, LLC, Holly M. Polglase (BBO #553271 Michael S. Batson (BBO #648151) Matthew E. Bown (BBO #687184) HERMES, NETBURN, O'CONNOR & SPEARING, P.C.

          Christopher W. Cardwell, Esq. (pro hac vice forthcoming GULLETT, SANFORD, ROBINSON & MARTIN, PLLC

          A2 MEDICAL, INC. Mark W. Batten (BBO No. 566211) PROSKAUER ROSE LLP

          STIPULATION AND ORDER CONCERNING CONFIDENTIALITY OF DOCUMENTS AND INFORMATION

         WHEREAS, the parties to this action anticipate exchanging documents and information during the course of this action that either Plaintiffs or Defendant will assert contain confidential, proprietary, trade secret, or personal information concerning the parties, third persons and/or the events and occurrences forming the subject of this action; The parties to this action, through their respective counsel of record, HEREBY STIPULATE to the following, and request that this Stipulation be entered as an Order of the Court:

         1. For the purposes of this Stipulation and [Proposed] Order Re Confidentiality of Documents and Information (the "Protective Order"), "Confidential Information" shall mean all documents, information or other materials (including the contents thereof) that contains sensitive non-public business information, proprietary, trade secret, or private information of a personal, financial or sensitive nature regarding: the parties to this action or any of their respective employees, contractors, suppliers, or customers. All information or material that the producing party believes in good faith fits within the above definition and is worthy of protection may be marked or designated "Confidential, " to be treated in accordance with the provisions of this Protective Order.

         2. Confidential Information produced in connection with this action may be used and retained for purposes of this action only.

         3. Access to and/or disclosure of all or any part of the Confidential Information shall be permitted only to the following persons (the "Designated Persons"):

(a) The parties to this action, including any person who joins this action as an opt-in.
(b) Witnesses who are deposed by any party in this action.
(c) Counsel for the parties to this action who are charged with responsibility for and are actively engaged in the preparation of this matter for trial and in the actual trial on this matter or any appeal therein ("Counsel"), and to Counsel's employees and independent contractors, such as paralegals, secretaries and clerical employees, who are actually involved in the preparation and/or trial of this action or any appeal therein.
(d) Employees and independent contractors of the parties (other than Counsel's paralegals and assistants) hired or retained solely for the purpose of prosecuting or defending this action.
(e) Experts and consultants retained by the parties to assist in the preparation and trial of this action.
(f) Court reporters at deposition and trial or in connection with any ...

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