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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Civil Action No. 07-cv-00630-DME-MEH
NETQUOTE INC, a Colorado corporation,
Plaintiff,
v.
BRANDON BYRD, an internet user making use of the IP Addresses 64.136.27.226 and
64.136.26.227, and
MOSTCHOICE.COM, INC., a Georgia corporation,
Defendants.
[Proposed] STIPULATED PROTECTIVE ORDER RE: SEARCH OF BRANDON
BYRD’S COMPUTER HARD DRIVE
WHEREAS, Plaintiff NetQuote, Inc. (“NetQuote”) has requested to inspect the contents
of Brandon Byrd’s hard drive for evidence relevant to the above-captioned lawsuit;
WHEREAS, Defendant Brandon Byrd (“Byrd”) has agreed to permit NetQuote to make a
forensic image of the hard drive and to inspect it pursuant to the terms of this Stipulated
Protective Order;
WHEREAS, a copy of the hard drive (the “Copy”) was forensically imaged at
NetQuote’s expense on June 1, 2007;
WHEREAS, the Copy was placed in a sealed evidence bag and is in the custody of
counsel for Byrd;
Case 1:07-cv-00630-DME-MEH Document 29 Filed 06/12/2007 Page 1 of 5
Netquote Inc. v. Byrd
Doc. 29
Dockets.Justia.com
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WHEREAS, counsel for Byrd has not and will not open the seal on the evidence bag or
otherwise manipulate the Copy;
NOW, THEREFORE, THE PARTIES HEREBY STIPULATE AND AGREE:
1.
NetQuote will select a vendor or vendors (the “Vendor”) to inspect the Copy.
Prior to the Vendor receiving the Copy, the Vendor shall execute an Agreement reading as
follows:
I hereby certify that _________________ (the “Vendor”) has been retained by
Faegre & Benson LLP to examine the forensic copy of the hard drive of Brandon
Byrd. The Vendor agrees to comply with the Stipulated Protective Order Re:
Search of Brandon Byrd’s Hard Drive entered by the United States District Court
for the District of Colorado (the “Court”) in Civ. No. 07-cv-00630-DME-MEH,
and that any violation of the Stipulated Protective Order will subject the Vendor
to appropriate sanctions as determined by the Court.
2.
Once NetQuote provides counsel for Byrd with a copy of the executed
Agreement