Filing Summary

This document, which was agreed to by the parties, and ordered by the Court governs the treatment of discovery materials in the litigation.

Key Points

• The designating party has the ability to designate disclosures in the case as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL.” (p.3)
• Highly confidential materials are defined as disclosures “reflecting non-public technical research, pricing and business strategy documents concerning a particular product or service, financial statements reflecting sales data, margin data, cost and expense data, human resource or personnel files, and/or profit data, sales information specific customers or classes of customers, [and] non-public research.” (p.3)
• Of note, highly confidential information may not be disclosed or disseminated to “William A. Brewer or to personnel within Brewer, Attorneys and Counselors who are members of the Public Relations Unit of the firm.” (P.12).  This provision has to do with Ackerman’s stated concern that Brewer’s firm also acts as crisis communication advisors to the NRA (a role Ackerman previously performed).