United States District Court, D. Nevada
CAMPBELL & WILLIAMS, J. COLBY WILLIAMS, ESQ., PHILIP R
ERWIN, ESQ., SAMUEL R MIRKOVICH, ESQ. Attorneys for
Defendants Station Casinos, LLC and NP Texas, LLC
OFFICES OF STEVEN J. PARSONS STEVEN J. PARSONS ANDREW L.
REMPFER JOSEPH N. MOTT Attorneys for Plaintiff Eva Perez
[PROPOSED] PROTECTIVE ORDER REGARDING CONFIDENTIAL
Plaintiff Eva Perez and Defendant Station Casinos, LLC and NP
Texas, LLC recognize that certain information related to the
subject matter of this action is sensitive and confidential.
More specifically, discovery in this employment dispute will
encompass confidential, private and other non-public
information including but not limited to personnel files,
personal health information and proprietary business
information. Because this type of information is non-public
and subject to protection by statute and/or common law, the
Parties stipulate and agree to the following Protective
Protective Order does not and will not govern any trial
proceedings in this action but is instead entered solely for
the purpose of facilitating the exchange of documents and
information among the parties to this action without
involving the Court unnecessarily in the process. Nothing in
this Protective Order, nor the production of any information
or document under the terms of this Protective Order, nor any
proceedings pursuant to this Protective Order shall be deemed
to be a waiver of any rights or objections to challenge the
authenticity or admissibility of any document, testimony or
other evidence at trial. Additionally, this Protective Order
will not prejudice the right of any party or nonparty to
oppose production of any information on the ground of
attorney-client privilege; work product doctrine or any other
privilege or protection provided under the law.
"Material" shall mean all documents, materials,
testimony, items, and/or other information regardless of the
medium or manner generated, stored, or maintained that are
produced or generated in disclosures or discovery either by a
party or by a non-party. The protections conferred by this
Protective Order cover not only Material designated as
"Confidential" as described below but also any
Material copied or extracted therefrom, as well as all
copies, excerpts, summaries, or compilations thereof, plus
testimony or presentations by parties or counsel that might
reveal Confidential Material.
"Receiving Party" shall mean a party that receives
Material from a Producing Party.
"Producing Party" shall mean a party or non-party
that produces Material in this Action.
party or non-party may designate as "Confidential"
any Material that such party or non-party in good faith
believes contains confidential or proprietary technical,
scientific, financial, business, health, medical,
investigatory or personal information, including any copy or
other reproductions, excerpts, summaries, abstracts, or other
documents that paraphrase, quote, or contain Confidential
Information. Each Producing Party that designates information
or items for protection under this Protective Order must take
care to limit any such designation to specific material that
qualifies under the appropriate standards. Indiscriminate
designations are prohibited.
Producing Party may designate Material it produced as
Confidential by notation on the document on each page that
contains Confidential. If only a portion or portions of the
Material on a page qualifies for protection, the Producing
Party also must clearly identify the protected portion(s).
Receiving Party or non-party may designate Material produced
by another party or non-party as Confidential by written
notice to all parties and/or the producing non-party of such
designation. After any such designation, such Material shall
be fully subject to this Protective Order and treated
thereafter according to the terms of this Protective Order as
party or third party may designate information disclosed
during a deposition as Confidential by so indicating on the
record at the deposition. A party or third party may also
designate such information as Confidential in writing, within
thirty (30) days of the receipt of the transcript ("the
designation period"), that specific pages of the
transcript be treated as Confidential.
the designation period has elapsed for a given deposition
transcript, all information contained or incorporated in that
transcript shall be treated as Confidential information.
information contained or incorporated in a deposition
transcript is designated as Confidential, the party making
the designation shall make arrangements with the court
reporter to label the relevant pages Confidential.
inadvertent failure to designate Material as Confidential
shall not be deemed, by itself, to be a waiver of the right
to so designate the Material and may be remedied by
supplemental written notice within a reasonable time after
such failure to designate is known. If such notice is given,
all Material so designated shall be fully subject to this
Protective Order as if it had been initially designated as
Confidential. After any designation is made in accordance
with this paragraph, counsel for all parties shall be
responsible for marking all previously unmarked copies of the
designated Material within their possession or control as
Confidential. Disclosure of Material to any other person
prior to a later designation of the Material as Confidential
in accordance with this Section shall not violate the terms
of this Protective Order. However, immediately upon being