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Kamimura v. Green Tree Services, LLC

United States District Court, D. Nevada

January 31, 2017

Lee C. Kamimura, individually and all others similarly situated, Plaintiff,
v.
Green Tree Services, LLC, Defendant.

          Michael Kind Attorneys for Plaintiff

          Laura R. Jacobsen Attorneys for Defendant Green Tree Servicing LLC, now known as Ditech Financial LLC

          [PROPOSED] PROTECTIVE ORDER

         The parties have agreed to the terms of this Protective Order; accordingly, it is ORDERED:

         1. Scope.

         All documents produced in the course of discovery, including initial disclosures, all responses to discovery requests, all responses to third-party subpoenas, all deposition testimony and exhibits, other materials which may be subject to restrictions on disclosure for good cause and information derived directly therefrom (hereinafter collectively “document(s)”), shall be subject to this Order concerning confidential information as set forth below. This Order is subject to the Local Rules of this District and of the Federal Rules of Civil Procedure on matters of procedure and calculation of time periods.

         2. Form and Timing of Designation.

         A party may designate documents as confidential and restricted in disclosure under this Order by placing or affixing the words “CONFIDENTIAL” on the document in a manner that will not interfere with the legibility of the document and that will permit complete removal of the CONFIDENTIAL designation. Documents shall be designated CONFIDENTIAL prior to or at the time of the production or disclosure of the documents. The designation “CONFIDENTIAL” does not mean that the document has any status or protection by statute or otherwise except to the extent and for the purposes of this Order.

         3. Documents Which May be Designated CONFIDENTIAL.

         Any party may designate documents as CONFIDENTIAL but only after review of the documents by an attorney who has in good faith determined that the documents contain information protected from disclosure by statute or that should be protected from disclosure as confidential personal information, trade secrets, personnel records, or commercial information. The designation shall be made subject to the standards of Rule 11 and the sanctions of Rule 37 of the Federal Rules of Civil Procedure. Information or documents that are available in the public sector may not be designated as CONFIDENTIAL.

         4. Depositions.

         Deposition testimony will be deemed CONFIDENTIAL only if designated as such either during the Deposition or within 30 days following the receipt of the Deposition Transcript. Within thirty (30) days after delivery of the transcript, a designating party may serve a Notice of Designation to all parties of record as to specific portions of the transcript to be designated CONFIDENTIAL. Such designation shall be specific as to the portions to be designated CONFIDENTIAL. The entire deposition testimony shall be treated as CONFIDENTIAL until the 30 days to designate specific portions of the transcript has elapsed. Thereafter, those portions designated as CONFIDENTIAL by either party shall be protected as CONFIDENTIAL pending objection under the terms of this Order.

         5. Protection of Confidential Material.

         a. General Protections. Documents designated CONFIDENTIAL under this Order shall not be used or disclosed by the parties, counsel for the parties or any other persons identified in ¶ 5.b. for any purpose whatsoever other than to prepare for and to conduct discovery, hearings and trial in this action, including any appeal thereof.

         b. Limited Third-Party Disclosures. The parties and counsel for the parties shall not disclose or permit the disclosure of any CONFIDENTIAL documents to any third person or entity except as set forth in subparagraphs 1-6. Subject to these requirements, the following categories of persons may be allowed to review documents that have been designated CONFIDENTIAL:

1. The Court and Court personnel;
2. Counsel. Counsel for the parties and employees of counsel who have responsibility for the preparation and trial of the action;
3. Parties. Parties and employees of a party to this Order, but only to the extent counsel determines that the specifically named individual party or employee's assistance is reasonably necessary to the conduct of ...

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