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Skinner v. Geico Casualty Insurance Co.

United States District Court, D. Nevada

March 20, 2017

MARISSA SKINNER, individually, Plaintiff,
v.
GEICO CASUALTY INSURANCE COMPANY, individually; and DOES I through X; and ROE CORPORATIONS I through X, inclusive, Defendants.

          Priscilla L. O'Briant ROBERT W. FREEMAN, ESQ. Nevada Bar No. 03062 PRISCILLA L. O'BRIANT, ESQ Attorneys for Defendant.

          Lukas B. McCourt BRIAN P. CLARK, ESQ. Nevada Bar No. 04236 LUKAS B. MCCOURT, ESQ. Nevada Bar No. 11839 Attorneys for Plaintiff.

          STIPULATED CONFIDENTIALITY AGREEMENT AND PROTECTIVE ORDER

         It appearing to the Court that the Plaintiff MARISSA SKINNER (“Plaintiff”) and Defendant GEICO CASUALTY COMPANY (incorrectly sued as GEICO CASUALTY INSURANCE COMPANY, hereinafter (“GEICO”) are in agreement that GEICO possesses proprietary policies and procedures that include confidential information that may be subject to discovery in the proceedings in this matter but which should not be made available to the public generally, this Court hereby orders that:

         1. This Confidentiality Agreement and Protective Order shall govern certain discovery and document production among the parties, as well as discovery and document production from third parties, in the above-referenced action.

         2. For purposes of this Confidentiality Agreement and Protective Order, the term "Confidential Information" shall refer to: (1) information which any party or non-party believes in good faith to be a trade secret or confidential research, development, commercial, or other proprietary business information within the meaning of NRCP 26(c)(7) Fed.R.Civ.P. 26(c)(1)(G) and (2) documents and/or testimony that may reveal confidential, proprietary, personal, or commercially sensitive information. Such Confidential Information may be contained in any written, printed, recorded, or graphic matter of any kind and shall retain its confidential designation regardless of the medium on which it is produced, reproduced, or stored. Such Confidential Information may also be elicited at deposition or through written discovery.

         3. Whenever any party or non-party desires to designate information contained in a document as Confidential Information, the designating party shall mark each page of the document with the word "CONFIDENTIAL" and identify such Confidential Information at the time of production. Confidential Information may be used in the course of depositions in accordance with this Confidentiality Order.

         4. If any Party disagrees with the designation of materials marked “Confidential, ” the objecting Party shall within five (5) days of receipt of the materials, provide written notice of the disagreement to GEICO, requesting a meeting to confer with counsel for GEICO to resolve the dispute over the “Confidential” designation. If the dispute over the designation is not resolved informally between the parties, GEICO will file a motion with the Court to resolve the dispute regarding the “Confidential” designation. GEICO will have 30 days from the date in which the parties meet and confer regarding the dispute over the designation, in which to file a motion with the court regarding the designation. In any event, unless and until a Court ruling is obtained changing a designation, or the Party designating the materials as “Confidential” agrees otherwise in writing, the material involved shall be treated according to the existing “Confidential” designation.

         5. Transcripts or exhibits from any deposition or hearing shall be temporarily designated as “Confidential” and be treated as subject to the terms of this Stipulation. Within forty-five (45) days of receipt of such transcripts and exhibits, Counsel will designate the pages of the transcripts or exhibits which shall remain designated as “Confidential” and will advise all other parties. If no designation is made within forty-five (45) days, the entire transcript and all exhibits will be deemed not confidential.

         6. All documents produced or information disclosed and any other records designated as “confidential” by GEICO shall be revealed only to:

a) Plaintiff;
b) Plaintiff's counsel of record in this case;
c) Defendant;
d) Defendant's counsel of record in this case;
e) Paralegals and secretarial employees under counsels' ...

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