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Nagy v. Western Alliance Bank

United States District Court, D. Nevada

March 10, 2017

OMAR NAGY, an individual, Plaintiff,
v.
WESTERN ALLIANCE BANK, d/b/a “BANK OF NEVADA”, Defendant.

          Suzanne L. Martin, Marcus B. Smith, Ogletree, Deakins, Nash, Smoak & Stewart, P.C., Attorneys for Defendant Western Alliance Bank dba Bank of Nevada.

          Andrew L. Rempfer, Attorneys for Plaintiff.

          STIPULATED PROTECTIVE ORDER CONCERNING CONFIDENTIAL INFORMATION

         Plaintiff Omar Nagy (“Plaintiff”) and Defendant Western Alliance Bank dba Bank of Nevada (“Defendant”) (collectively, the “Parties”), through their counsel of record, requests the Court enter the following Stipulated Protective Order Concerning Confidential Information. This Stipulation is filed pursuant to Local Rule 7-1.

         I.CONFIDENTIAL MATERIAL

         The Parties agree there are certain categories of information and documents that deserve protection from disclosure. The Parties agree disclosure of this information to individuals not associated with this litigation may harm the Parties, their respective businesses interests, and customers. The parties will keep ‘confidential' the proceeding “Confidential Information.” “Confidential Information, ” consists of:

(a) any documents or other information which counsel in good faith believe contain confidential or proprietary business information, including customer names, accounts or financial information;
(b) any documents or other information which counsel in good faith believe contain or relate to confidential bank operations, the public disclosure of which would be detrimental to Defendant or its customers;
(c) any documents or other information which counsel in good faith believe relate to credit or financing transactions by Defendant or its customers, including the value of any loan, the collateral for a loan, the addresses of properties being purchased as part of a loan transaction, and other non-public information regarding Defendant's customers produced by Defendant; and
(d) Plaintiff's protected health information, law school records, and non-public information regarding businesses in which Plaintiff has an ownership interest, or is invested, or operates.

         Confidential Information shall be confidential, and maintained as confidential, in accordance with the terms of this Stipulated Protective Order Concerning Confidential Information. “Confidential Information” includes any portion of documents, discovery responses, testimony, or other discovery materials containing Confidential Information.

         II. USE OF CONFIDENTIAL MATERIAL

         “Confidential Information” described in Section I above may only be used for purposes of this litigation, and may be only disclosed with the consent of the parties, or by Court Order, to the following persons:

(a) The Court, and Court personnel involved in this case (including court reporters and persons operating video recording equipment at depositions);
(b) The Parties' counsel of record in this action, including their partners, associates, secretaries, legal assistants, clerical staff, and employees working with, or under the supervision of counsel, to the extent reasonably ...

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