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RIMINI STREET, INC. v. ORACLE INTERNATIONAL CORPORATION, 2:14-cv-01699 LRH PAL. (2016)

Court: District Court, D. Nevada Number: infdco20160328c81 Visitors: 9
Filed: Mar. 25, 2016
Latest Update: Mar. 25, 2016
Summary: STIPULATED SUPPLEMENTAL PROTECTIVE ORDER CONCERNING DOCUMENTS PRODUCED PURSUANT TO THE PARTIES' TECHNOLOGY-ASSISTED REVIEW PROTOCOL PEGGY A. LEEN , Magistrate Judge . WHEREAS, the Court entered a Stipulated Protective Order on May 18, 2015 (Dkt. 58); WHEREAS, Plaintiff and Counterdefendant Rimini Street, Inc. and Counterdefendant Seth Ravin (together, "Rimini") and Counterclaimant Oracle America, Inc. and Defendant and Counterclaimant Oracle International Corp. (together, "Oracle"; all p
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STIPULATED SUPPLEMENTAL PROTECTIVE ORDER CONCERNING DOCUMENTS PRODUCED PURSUANT TO THE PARTIES' TECHNOLOGY-ASSISTED REVIEW PROTOCOL

WHEREAS, the Court entered a Stipulated Protective Order on May 18, 2015 (Dkt. 58);

WHEREAS, Plaintiff and Counterdefendant Rimini Street, Inc. and Counterdefendant Seth Ravin (together, "Rimini") and Counterclaimant Oracle America, Inc. and Defendant and Counterclaimant Oracle International Corp. (together, "Oracle"; all parties collectively, "Parties," any party, "Party") have agreed that the Stipulated Protective Order (Dkt. 58) should be amended to add the following provisions to better effectuate the Parties' proposed technology-assisted review protocol, Dkt. 106, Ex. A (the "TAR Protocol");

WHEREAS, the Parties have agreed that all paragraph references and defined terms below refer to the paragraphs and definitions of the Stipulated Protective Order unless otherwise stated;

NOW, THEREFORE, IT IS STIPULATED BY AND BETWEEN THE PARTIES THROUGH THEIR RESPECTIVE COUNSEL OF RECORD, AS FOLLOWS:

24. All documents and other materials produced pursuant to the TAR Protocol or any subsequent version thereof agreed to by the Parties ("TAR Documents") shall be produced with a metadata field that identifies them as TAR Documents.

25. All TAR Documents shall be designated and treated by all Parties as "Highly Confidential Information — Attorneys' Eyes Only" at the time of production.

26. Notwithstanding any provisions in Paragraph 16 to the contrary, any challenge to a Designating Party's confidentiality designation of any TAR Documents may be initiated either in writing or via voice-to-voice dialogue. Any such challenge must identify the challenged confidentiality designations by the Bates number(s) of the corresponding TAR Documents. The Designating Party shall respond in writing to any such challenge within ten (10) days. If the Parties are unable to resolve any dispute regarding a challenge to a Designating Party's confidentiality designation of TAR Documents, the Parties will submit their dispute(s) to the Court in the manner approved by the Court for raising discovery disputes in this case. For the avoidance of doubt, Paragraph 16 otherwise remains in full force and effect.

27. For the avoidance of doubt, the ten-day deadline set forth in Paragraph 26 will be calculated pursuant to Federal Rule of Civil Procedure 6(a)(1). Federal Rule of Civil Procedure 6(d)'s three-day extension for documents served electronically does not apply to the ten-day deadline.

28. The Parties may modify this procedure, including but not limited to the deadline set forth in Paragraph 26, for any set of TAR Documents through written agreement without further order of the Court.

IS IT SO ORDERED.

Source:  Leagle

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