United States District Court, D. Nevada
JENNIFER NUNES, a Nevada citizen; DENNYS SIAN, a Nevada citizen; RAMONA WELLS, a Nevada citizen; JAYSON MORGAN, a Nevada citizen, and KEYATRA GRANT, a Nevada citizen, Plaintiff,
AFFINITYLIFESTYLES.COM, INC. d/b/a REAL WATER, a Nevada corporation, ROE Defendants 1-100, Defendants.
amended on p. 12
BRISBOIS BISGAARD & SMITH LLP Josh Cole Aicklen, Esq.
David B. Avakian, Esq. Paige S. Shreve, Esq.
BRISBOIS BISGAARD & SMITH, LLP Attorneys for
Defendant AFFINITYLiFESTYLES.COM, INC. d/b/a REAL WATER
JONES & COULTHARD, LLP J. Randall Jones, Esq. Michael J.
Gayan, Esq. Nathanael R. Rulis, Esq. KEMP JONES &
COULTHARD, LLP Attorneys for Plaintiffs JENNIFER NUNES;
DENNYS SIAN; RAMONA WELLS; JAYSON MORGAN And KEYATRA GRANT
CONFIDENTIALITY STIPULATION AND PROTECTIVE
PURPOSES AND LIMITATIONS
and discovery activity in this action are likely to involve
production of confidential, proprietary, or private
information for which special protection from public
disclosure and from use for any purpose other than
prosecuting this litigation may be warranted. Accordingly,
the parties hereby stipulate to and petition the court to
enter the following Stipulated Protective Order, The parties
acknowledge that this Order does not confer blanket
protections on all disclosures or responses to discovery and
that the protection it affords from public disclosure and use
extends only to the limited information or items that are
entitled to confidential treatment under the applicable legal
principles. The parties further acknowledge, as set forth in
Section 12.3, below, that this Stipulated Protective Order
does not entitle them to file confidential information under
seal; Nevada/Federal law sets forth the procedures that must
be followed and the standards that will be applied when a
party seeks permission from the court to file material under
Challenging Party: a Party or Non-Party that
challenges the designation of information or items under this
"CONFIDENTIAL" Information or Items:
information (regardless of how it is generated, stored or
maintained) or tangible things that qualify for protection
under Federal Rule of Civil Procedure 26(c).
Counsel (without qualifier): Outside Counsel of Record and
House Counsel (as well as their support staff)
Designing Party: a party or Non-Party that designates
information or items that it produces in disclosures or in
responses to discovery as "CONFIDENTIAL."
Disclosure or Discovery Material: all items or
information, regardless of the medium or manner in which it
is generated, stored, or maintained (including, among other
things, testimony, transcripts, and tangible things), that
are produced or generated in disclosures or responses to
discovery in this matter.
Expert: a person with specialized knowledge or
experience in a matter pertinent to the litigation who has
been retained by a Party or its counsel to serve as an expert
witness or as a consultant in this action.
House Counsel: attorneys who are employees of a
party to this action. House Counsel does not include Outside
Counsel of Record or any other outside counsel.
Non-Party: any natural person, partnership,
corporation, association, or other legal entity not named as
a Party to this action.
Outside Counsel of Record: attorneys who are not
employees of a party to this action but are retained to
represent or advise a party to this action and have appeared
in this action on behalf of that party or are affiliated with
a law firm which has appeared on behalf of that party.
Party: any party to this action, including all of
its officers, directors, employees, consultants, retained
experts, and Outside Counsel of Record (and their support
Producing Party: a Party or Non-Party that produces
Disclosure or Discovery Material in this action.
Professional Vendors: persons or entities that
provide litigation support services (e.g., photocopying,
videotaping, translating, preparing exhibits or
demonstrations, and organizing, storing, or retrieving data
in any form or medium) and their employees and
Protected Material: any Disclosure or Discovery
Material that is designated as "CONFIDENTIAL."
Receiving Party: a Party that receives Disclosure or
Discovery Material from a Producing Party.
protections conferred by this Stipulation and Order cover not
only Protected Material (as defined above), but also (1) any
information copied or extracted from Protected Material; (2)
all copies, excerpts, summaries, or compilations of Protected
Material; and (3) any testimony, conversations, or
presentations by Parties or their Counsel that might reveal
Protected Material. However, the protections conferred by
this Stipulation and Order do not cover the following
information: (a) any information that is in the public domain
at the time of disclosure to a Receiving Party or becomes
part of the public domain after its disclosure to a Receiving
Party as a result of publication not involving a violation of
this Order, including becoming part of the public record
through trial or otherwise; and (b) any information known to
the Receiving Party prior to the disclosure or obtained by
the Receiving ...