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Board of Trustees of Plumbers and Pipefitters Union Local 525 Health and Welfare Trust and Plan v. Yard Plumbing, Inc.

United States District Court, D. Nevada

March 14, 2017

BOARD OF TRUSTEES OF THE PLUMBERS AND PIPEFITTERS LOCAL 525 HEALTH AND WELFARE TRUST AND PLAN; BOARD OF TRUSTEES OF THE PLUMBERS AND PIPEFITTERS UNION LOCAL 525 PENSION PLAN; AND BOARD OF TRUSTEES OF PLUMBERS AND PIPEFITTERS LOCAL UNION 525 APPRENTICE AND JOURNEYMAN TRAINING TRUST FOR SOUTHERN NEVADA, Plaintiffs,
v.
YARD PLUMBING, INC., a Nevada Corporation; DEANNE YARD, an individual; FREEMAN EXPOSITIONS, INC., a Texas Corporation; GLOBAL EXPERIENCE

          Bryan Johnson Chelsea Larsen Designation for Service Only: Damon Schuetze Attorneys for Defendants YARD PLUMBING, INC., DEANNE YARD, EDLEN ELECTRICAL EXHIBITION SERVICES, INC., ARATA EXPOSITIONS, INC., PREMIER SERVICES, INC., and PLATTE RIVER INSURANCE COMPANY

          David Dornak Counsel for Defendants, Global Experience Specialists, Inc. and Freeman Expositions, Inc.

          Christopher Humes Counsel for Plaintiff

          [PROPOSED] STIPULATED AGREED CONFIDENTIALITY ORDER

         The parties to this Stipulated Agreed Confidentiality Order have agreed to the terms of this Order; accordingly, it is ORDERED:

         1. Scope.

         All documents produced in response to subpoenas and during discovery (hereinafter collectively “documents”), including without limitation the subpoena issued to Bank of America on or about February 8, 2017 and the subpoenas issued to Jeff Schermerhorn and Derek Schermerhorn on or about February 13, 2017, shall be subject to this Order concerning Confidential Information as defined below. This Order is subject to the Local Rules of this District and the Federal Rules of Civil Procedure on matters of procedure and calculation of time periods.

         2. Confidential Information.

         As used in this Order, “Confidential Information” means information designated as “CONFIDENTIAL-SUBJECT TO PROTECTIVE ORDER” by the producing party that falls within one or more of the following categories: (a) information prohibited from disclosure by statute; (b) research, technical, commercial or financial information that the party has maintained as confidential; (c) personal identity information; (d) income tax returns (including attached schedules and forms), W-2 forms and 1099 forms; (e) trade secrets and proprietary information and records, or (f) personnel or employment records of a person who is not a party to the case. Information or documents that are available to the public may not be designated as Confidential Information.

         3. Designation.

         (a) A party may designate a document as Confidential Information for protection under this Order by placing or affixing the words “CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER” on the document and on all copies in a manner that will not interfere with the legibility of the document. As used in this Order, “copies” includes electronic images, duplicates, extracts, summaries or descriptions that contain the Confidential Information. The marking “CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER” shall be applied prior to or at the time of the documents are produced or disclosed. Applying the marking “CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER” to a document does not mean that the document has any status or protection by statute or otherwise except to the extent and for the purposes of this Order. Any copies that are made of any documents marked “CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER” shall also be so marked, except that indices, electronic databases or lists of documents that do not contain substantial portions or images of the text of marked documents and do not otherwise disclose the substance of the Confidential Information are not required to be marked.

         (b) The designation of a document as Confidential Information is a certification by an attorney or a party appearing pro se that the document contains Confidential Information as defined in this order.

         (c) Any party may, on the record of a deposition, or within twenty business days after receipt of the transcript of such deposition, designate any portion or portions of a deposition as “CONFIDENTIAL - SUBJECT TO PROTECTIVE ORDER.” During the twenty business days following receipt of such deposition transcript, the entire deposition transcript shall be treated as “Confidential” unless otherwise specified in writing or on the record of the deposition by the designating party.

         4. Protection of Confidential Material.

         (a) General Protections.

         Confidential Information shall not be used or disclosed by the parties, counsel for the parties or any other persons identified in subparagraph (b) for any purpose whatsoever other than in this litigation, including any appeal thereof.

         (b) Limited Third-Party Disclosures.

         The parties and counsel for the parties shall not disclose or permit the disclosure of any Confidential Information to any third person or entity except as set forth in subparagraphs (1)-(9). Subject to these requirements, the following categories of persons may be allowed to review Confidential Information:

         (1) Inside and Outside Counsel.

         Counsel for the parties and employees of counsel who have responsibility for the action;

         (2) Parties. Individual parties and officers, directors and employees of a party but only to the extent counsel determines in good faith that the officers, directors and employee's assistance is reasonably necessary to the conduct of the litigation in which the information is disclosed;

         (3) The Court and its personnel;

         (4) Court Reporters and Recorders.

         Court reporters and recorders ...


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