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Perez v. Station Casinos, LLC

United States District Court, D. Nevada

February 2, 2017

EVA PEREZ, an individual, Plaintiff,
v.
STATION CASINOS, LLC, a Nevada limited liability company; NP TEXAS, LLC a Nevada limited liability company; PAUL NELSON, an individual; NELSON ROMANO, an individual, Defendants.

          CAMPBELL & WILLIAMS, J. COLBY WILLIAMS, ESQ., PHILIP R ERWIN, ESQ., SAMUEL R MIRKOVICH, ESQ. Attorneys for Defendants Station Casinos, LLC and NP Texas, LLC

          LAW OFFICES OF STEVEN J. PARSONS STEVEN J. PARSONS ANDREW L. REMPFER JOSEPH N. MOTT Attorneys for Plaintiff Eva Perez

          [PROPOSED] PROTECTIVE ORDER REGARDING CONFIDENTIAL INFORMATION

         WHEREAS 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 Order:

         This 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.

         Definitions.

         1. "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.

         2. "Receiving Party" shall mean a party that receives Material from a Producing Party.

         3. "Producing Party" shall mean a party or non-party that produces Material in this Action.

         Designation of Materials.

         4. Any 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.

         5. A 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).

         6. A 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 Confidential Material.

         7. A 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.

         Until the designation period has elapsed for a given deposition transcript, all information contained or incorporated in that transcript shall be treated as Confidential information.

         When 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.

         8. The 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 ...


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