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Unusyan v. Geico Casualty Co.

United States District Court, D. Nevada

March 17, 2017

MARTIN UNUSYAN, an individual Plaintiff,
v.
GEICO CASUALTY COMPANY, a foreign corporation, DOES I through XV, and ROE Corporations I through X, inclusive, Defendants.

          ATKIN WINNER & SHERROD BRUCE W. KELLEY, ESQ. Nevada Bar No. 7331 ARIEL C. JOHNSON, ESQ. Nevada Bar No, 13357 LARA L. MILLER, ESQ. Nevada Bar No, 12618 Attorneys for GEICO CASUALTY COMPANY

          LAW OFFICE OF GINA M. CORENA GINA M. CORENA, ESQ. Nevada Bar No. 10330 KRISTA J, NIELSON, ESQ, Nevada Bar No, 10698 Attorneys for MARTIN UNUSYAN

          STIPULATION TO CONFIDENTIALITY AND PROTECTIVE ORDER

         IT IS HEREBY STIPULATED by and between all parties: Plaintiff MARTIN UNUSYAN, by and through his counsel of record Gina M. Corena, Esq. and Krista J. Nielson of the LAW OFFICE OF GINA M. CORENA, and Defendant GEICO CASUALTY COMPANY, by and through its counsel of record, Bruce W. Kelley, Esq., Ariel C. Johnson, Esq., and Lara L. Miller, Esq. as follows:

         1. The parties agree that certain documents and data produced in this litigation contain confidential information. A document containing confidential information shall be designated by marking the document with a watermark indicating "Proprietary or Confidential Information - Subject to Protective Order, Case No. 2:16-cv-02007-APG-VCF."

         2. Except as otherwise provided in this stipulation or by further order of the court, all documents designated confidential shall be used only for purposes of this litigation and shall be disclosed only to the parties and their attorneys (including secretarial and legal staff); and to any consultant retained by the parties as a potential or actual expert witness in this litigations. All such individuals who are given access to the Confidential Information must first agree to be bound by the terms of this Stipulation and Protective Order by signing the "Acknowledgment of Stipulation and Protective Order, " attached as Exhibit A to that Order.

         3. For any deposition transcript that contains testimony concerning Confidential Information, or which includes any document containing Confidential Information that is marked as an exhibit, each such deposition shall be designated as "Subject to Protective Order, Case No. 2:16-cv-02007-APG-VCF" on the record during said deposition, placed under seal, and shall be subject to the terms of the Stipulated Protective Order.

         4. When this litigation is concluded by judgment, settlement, dismissal or otherwise, the provisions of this protective order shall remain in effect and each such confidential document (and all copies thereof) shall be returned within forty-five (45) days of conclusion of the case to counsel for the party that produced the confidential document.

         5. All documents so marked confidential may be referred to or incorporated in briefs, affidavits, or other documents filed with the court provided that such documents are either: (1) filed with the Clerk of Court under seal and prominently marked "Proprietary or Confidential Information - Subject to Protective Order Case, No. 2:16-cv-02007-APG-VCF"; and (2) in a manner pursuant to United Stated District Court Nevada Local Rule IA lO-S(a).[1]

         6. The stipulation/protective order shall remain in. effect until further order of the court.

         STIPULATED PROTECTIVE ORDER REGARDING CONFIDENTIAL DOCUMENTS United State Federal District Court District of Nevada Case No.: 2:l6-cv-02007-APG-VCF

         The parties, Plaintiff MARTIN UNUSYAN; and Defendant GEICO CASUALTY COMPANY; by and through their respective counsel of record, acknowledge that certain documents produced in the subject consolidated action contain confidential information including, but not limited to, trade secrets; confidential research, development or commercial information; financial information; process and training materials; and other sensitive, 'nonpublic information (collectively, "Confidential Information").

         The Court, being advised of the agreement of the parties to the entry of this Stipulated Protective Order, HEREBY ORDERS AS FOLLOWS:

         1, This Stipulated Protective Order shall apply to all confidential information, properly designated as described in Paragraph 4, which is produced in this litigation, 2. In connection with discovery proceedings in the Litigation, any party to the Litigation (the "Designating Party") shall have the right to designate as "Confidential" any testimony, documents, and other material containing Confidential Information, the disclosure of which in a manner other than that specified herein the Designating Party in good faith believes would present a significant risk of injury to the legitimate business interests of the disclosing party or a significant risk of injury to any other legitimate interest. Such Confidential Information includes, but is not limited to, proprietary trade secrets; all materials reflecting, referring to or evidencing any information deemed confidential by local, state, or federal statute, ordinance, regulation, or Other law; confidential non-public business plans or forecasts; confidential non-public financial plans and forecasts; all private or sensitive commercial, financial, personal or personnel information; confidential non-public underwriting and rating information; training manuals, guidelines and other proprietary process documentation; and confidential research and development information. Confidential Information also includes, but is not limited to, personal information such as a person's social security number, medical records, personnel file, bank records, tax records and other sensitive non-public information. Confidential Information may take the form of, but is not limited to, (a) documents, interrogatories, requests for admission, and answers and responses thereto; (b) transcripts of depositions and exhibits thereto; and (c) all copies, abstracts, excerpts, analyses, and complete or partial summaries prepared from or containing, reflecting, or disclosing such Confidential Information.

         3. Confidential Information may be disclosed only to "Qualified Persons, " as that term is defined in Paragraph 5 below, and used only in connection with this litigation and for no other purpose. All Qualified Persons receiving Confidential Information ...


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