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Robinson v. Dungarvin Nevada, LLC

United States District Court, D. Nevada

January 24, 2017

JAMES E. ROBINSON, PRO SE Plaintiff,
v.
DUNGARVIN NEVADA, L.L.C., CHARLOTTE MCCLANAHAN, AND BARBARA JORDAN Defendants

          LIPSON, NEILSON, COLE, SELTZER & GARIN, P.C. Joseph P. Garin (Bar No. 6653) Jessica A. Green (Bar No. 12383) Attorneys for Defendants

          James E. Robinson Pro Se Plaintiff

          STIPULATED PROTECTIVE ORDER

          HONORABLE PEGGY A. LEEN UNITED STATES MAGISTRATE JUDGE

         In order to protect the confidentiality of sensitive and confidential information obtained by the parties in connection with this case, the parties hereby agree as follows:

         1. Any party or non-party may designate as “confidential” (by stamping the relevant page or as otherwise set forth herein) any document or response to discovery which that party or non-party considers in good faith to contain confidential information involving proprietary information, confidential business, financial, health, or personal information subject to protection under the Federal Rules of Civil Procedure, or federal or Nevada law (“Confidential Information”). Where a document or response consists of more than one page, the first page, and each page on which confidential information appears shall be so designated.

         2. A party or non-party may designate information disclosed during a deposition or in a response to written discovery as “confidential” so indicating in said response or on the record at the deposition and requesting the preparation of a separate transcript of such material. Additionally, a party or non-party may designate in writing, within twenty (20) days after a receipt of said responses or of the deposition transcript for which the designation is proposed, that specific pages of the transcript and/or specific responses be treated as “confidential” information. Any other party may object to such proposal, in writing or on the record. Upon such objection, the parties shall follow the procedures described in paragraph 8 below. After any designation made according to the procedure set forth in this paragraph, the designated documents or information shall be treated according to the designation until the matter is resolved according to the procedures described in paragraph 8 below, and each party shall be responsible for making all previously unmarked copies of the designated material in their possession or control with the specified designation.

         3. All information produced or exchanged in the course of this case (other than information that is publicly available) shall be used by the party or parties to whom the information is produced solely for the purpose of this case.

         4. Except with the prior written consent of the parties, or upon order of this Court obtained upon notice to the opposing party, Confidential Information shall not be disclosed to any person other than:

a. Counsel for the respective parties to this litigation, including in-house, corporate, and co-counsel retained for this litigation;
b. Employees of such counsel;
c. Individual parties to the lawsuit;
d. Officers or employees of a party, to the extent deemed necessary for the prosecution or defense of this litigation;
e. Consultants or expert witnesses retained for the prosecution or defense of this litigation, provided each such person shall execute a copy of the Certification annexed to this Order as “Exhibit A” (which shall be retained by counsel to the party so disclosing the Confidential Information and made available for inspection by the opposing party during the pendency or after the termination of the action only upon good cause shown and upon order of the Court) before being shown or given any Confidential Information and provided that if the party chooses a consultant or expert employed by Dungarvin, or one of its competitors, the party shall notify the opposing party, or designating non-party, before ...

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