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Hutchison v. Vons Companies, Inc.

United States District Court, D. Nevada

February 8, 2017

MARK HUTCHISON, individually, Plaintiff,
v.
THE VONS COMPANIES INC.; DOES I through X, inclusive; and ROE CORPORATIONS I through X inclusive, Defendants.

          JONES WILSON LLP CORY M. JONES, ESQ. Nevada Bar No. 5028 Attorney for Plaintiff, MARK HUTCHISON.

          MORAN BRANDON BENDAVID MORAN LEW BRANDON, JR., ESQ. Nevada Bar No. 5880 KRIS D. KLINGENSMITH, ESQ. Nevada Bar No. 13904 Attorneys for Defendant, THE VONS COMPANIES, INC.

          STIPULATED PROTECTIVE ORDER

         In connection with the production of confidential documents and other confidential information in this action, Plaintiff, MARK HUTCHISON (the “Plaintiff”), Defendant, THE VONS COMPANIES, INC. (the “Defendant”), through their respective counsel (“Plaintiff” and “Defendant” may also be collectively referred to as, the “Parties” or individually as, “Party”), hereby enter into this Stipulated Protective Order (“Stipulated Protective Order”).

         PURPOSE OF THIS PROTECTIVE ORDER

         The purpose of this Stipulated Protective Order is to provide a means for limiting access to and use and disclosure of Confidential Documents or Information produced in this action. Any unauthorized disclosure of Confidential Documents or Information in violation of this Order may be subject to discipline by the contempt powers of this United States District Court for the District of Nevada.

         DESIGNATION OF “CONFIDENTIAL DOCUMENTS OR INFORMATION”

         The Parties may designate such documents or information as “Confidential” in accordance with the following procedures:

         A.Confidential” Documents or Information.

         Either Party may designate any documents, records, reports, video tapes, tangible items, or information as “Confidential.” Upon a designation of “Confidential, ” the Parties shall treat any designated document, record, report, video tape, tangible item, or information as confidential and shall only use such document, record, report, video tape, tangible item, or information solely for the prosecution or defense of this matter.

         B. Time of Designation

         Unless otherwise agreed between counsel for the Parties, the designation of Confidential Documents or Information shall be made at the time of the production of documents, records, reports, video tapes, tangible items, or information.

         C. Manner of Designation

         The designation of Confidential Documents or Information shall be made in the following manner:

         1. For documents, by placing the notation “Confidential” on each page of such document;

         2. For tangible items, including any video tapes or documents or information produced on magnetic disks or other computer related media, by placing the notation “Confidential” on the object and, if applicable, on the container thereof or if such are not practicable, as otherwise agreed by the Parties. In the event either Party generates any “hard copy” or printout from any “Confidential Material, ” that Party must immediately stamp each page “Confidential, ” and the hard copy or printout shall be treated as “Confidential Information pursuant to this Stipulated Protective Order.”

         D. Retroactive Designation

         1. Inadvertent production of any Confidential Documents or Information without a designation of confidentiality will not be deemed to waive a later claim as to confidentiality or privilege, or prevent the Party claiming confidentiality from re-designating such documents or information as “Confidential” promptly after discovery of the inadvertent production.

         2. Within a reasonable time after production, either Party may retroactively designate (or withdraw a designation) of Confidential Documents or Information, regarding any material that it has produced, provided however, that such retroactive designation (or withdrawal) shall be in accordance with the terms of this Order. Such retroactive designation (or withdrawal) shall be accomplished by notifying counsel for the non-designating Party in writing of such retroactive designation (or withdrawal). Upon receipt of any such written re-designation, counsel (i) shall not make any further disclosure or communication of such retroactively designated material except as provided for in this Order; (ii) shall take reasonable steps to notify all persons known to have possession of any retroactively designated material of the effect of such re-designation under this Order; and (iii) shall take reasonable steps to procure all copies of such retroactively designated material from any persons known to have possession of any such retroactively designated material who are not entitled to receipt under this Order.

         E. Resolution of Disputes Regarding Designation

         If either Party, at any time, wishes to have the “Confidential” designation of any particular Confidential Documents or Information removed or changed, that Party shall first request in writing that the Party having made the designation at issue change its designation. Thereafter, the Parties shall make good faith efforts to resolve the dispute. If the designating Party refuses to agree to remove or change the designation, then the Party that requests that the designation be so removed may make a motion before this Court for an order removing or changing the designation; provided, however, that the designating Party shall have the burden of proving that such particular Confidential Document or Information are properly designated as “Confidential” pursuant to paragraph III below. At all times during the process of challenging a designation, the Parties shall treat the Confidential Documents or Information as originally designated until a change is agreed to or the motion is decided by the Court and written notice of such decision is served on the Parties.

         Any motion filed with respect to this Stipulated Protective Order or documents labeled “Confidential” must comply with the local rules of the United States District Court for the District of Nevada.

         F. Designation of ...


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