United States District Court, D. Nevada
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
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
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:
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."
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.
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.
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.
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
stipulation/protective order shall remain in. effect until
further order of the court.
PROTECTIVE ORDER REGARDING CONFIDENTIAL DOCUMENTS United
State Federal District Court District of Nevada Case
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,
Court, being advised of the agreement of the parties to the
entry of this Stipulated Protective Order, HEREBY ORDERS AS
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.
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 ...