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Kocienski v. NRT Technologies, Inc.

United States District Court, D. Nevada

February 15, 2017


          LAW OFFICES OF DANIEL MARKS Daniel Marks, Esq. Attorney for Plaintiff.

          W. WEST ALLEN, ROBERT L. ROSENTHAL, HOWARD & HOWARD ATTORNEYS PLLC Attorneys for Defendant NRT Technology, Inc.


         Pursuant to Federal Rule of Civil Procedure 26(c), the Parties, John Kocienski ("Plaintiff) and NRT Technologies, Inc. ("Defendant") submit this proposed Stipulated Protective Order for the purpose of ensuring that confidential information exchanged in discovery and possibly submitted by the Parties in the above-referenced case is not disclosed to or used for any purpose outside of the above-captioned lawsuit.

         During the course of this case, documents and information considered confidential and/or sensitive by at least one of the Parties may be disclosed, including but not limited to employment records and/or information related to current and former employees and third-party individuals who are not parties to this litigation, personal identifying information for said nonparties, commercial, financial or other business proprietary information, and medical records.

         The Parties agree that a Protective Order is necessary in light of the need to protect confidential commercial, financial and proprietary information from public disclosure, the fact that the disclosure of confidential employment records and related information would potentially subject the Parties to liability from claims by such non-party employees, former employees, and/or third-party individuals, the disclosure of the confidential employment records of nonparty employees, former employees, and third-party individuals could harm such individuals, interfere with other job opportunities or relationships, impact their reputation, and cause them undue embarrassment and/or distress, the obligation to protect the confidential employment records of non-party individuals, and due to the sensitive nature of confidential investigations, the disclosure of which could harm the employees, former employees, or third-party individuals.

         For these reasons, the Parties hereby stipulate, subject to approval and entry by the Court, to the following:

         I. Definitions and Terms

         1. "Confidential Information" means any document, information, or material, which the producing party or protected person reasonably believes not to be in the public domain and reasonably believes contains proprietary or confidential information, or information to which an individual or company has an established and legitimate right to privacy or confidentiality, including any document, information, or material contained in any personnel file, medical records, confidential records, corporate records, financial records, donor lists, commercial or trade secret information of a sensitive and/or proprietary nature, competitive information and income tax records or information.

         2. "Disclosed" is used in its broadest sense and includes, inter alia, directly or indirectly shown, divulged, revealed, produced, described, transmitted or otherwise communicated, in whole or in part.

         3. "Discovery Material(s)" means any Confidential Information presented in documents, answers to interrogatories, responses to requests for admission, deposition testimony, deposition transcripts and exhibits, other responses to requests for information and/or written information, whether produced voluntarily or involuntarily, in response to discovery requests in this litigation by any party.

         4. "Document" is defined as the term is used in Federal Rule of Civil Procedure 34.

         5. "Under seal" is defined as sealing confidential documents consistent with the procedure laid out by Local Rule 10-5 and the Court's electronic filing procedures. In the event that the Court publishes a new procedure for the filing of documents under seal, the Parties may follow said published procedure.

         II. Types of Mater hi Is that May be Designated as Confidential

         Any Discovery Material, as defined above, may be designated by a producing party as Confidential under this Order. The assertion of this designation of "Confidential" shall constitute a representation to the Court that counsel for the producing party or protected person believes in good faith that the material so designated constitutes Confidential Information as defined in this Order. Except with the prior written consent of the producing party or by court order or as otherwise compelled by force ...

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