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Reader v. HG Staffing, LLC

United States District Court, D. Nevada

March 20, 2017

SARA READER (formerly LARSON), PAUL ALLEN, WENDY BASALLO, JUSTINE BRADLEY, ALEXIS BRYANT, TIFFANY CARRERA, SHENNA CORRAL, KATHERINE DOWLING, SHELLEY FAUST, CAITLIN GUNN, LIZ HEERAN, BRIDGETTE HINES, IMOGEN HOLT, STEPHANIE KNAUSS, JUSTINE LANG, MARK LARSON, GEORGE LOPES II, SANDRA MARTINEZ, MALCOLM MCCASKILL, JOSEPH MCKEE, MARIA MCKENZIE, CALLIE MIANO, TONY MORAN, JENNIFER NICHOLS, KAROLINA OLECH, NATALIE ORDAS, ARLENE OSORMAN, KATHRYN OWEN, STEVE PIERCE, ROXANNE PRIMUS, LAWRENCE RIORDAN SR., GAY ROBERTS, MELISSA ROSINA, MISTY SHELBY, BRANDI SMITH, KRYSTA STEIGLER, DELLENA THOMPSON, and ROBERT TRANCHIDA, on behalf of themselves and all others similarly situated, Plaintiffs,
v.
HG STAFFING, LLC, MEI-GSR HOLDINGS LLC d/b/a GRAND SIERRA RESORT, and DOES 1 through 50, inclusive, Defendants.

          THIERMAN BUCK, LLP Mark R. Thierman, Nev. Bar No. 8285 mark@thiermanbuck.com Joshua D. Buck, Nev. Bar No. 12187 josh@thiermanbuck.com Leah L. Jones, Nev. Bar No. 13161 leah@thiermanbuck.com Attorneys for Plaintiffs

          COHEN|JOHNSON|PARKER|EDWARDS H. Stan Johnson, Nev. Bar No. 00265 sjohnson@cohenjohnson.com Chris Davis, Nev. Bar No. 6616 cdavis@cohenjohnson.com Attorneys for Defendants

          STIPULATED PROTECTIVE ORDER

         In order to protect the confidentiality of confidential, private, and personal information obtained by the Parties in connection with this case, the Parties hereby agree to the entry of this Stipulated Protective Order submitted by Plaintiffs and Defendant HG STAFFING, LLC, MEI-GSR HOLDINGS LLC d/b/a GRAND SIERRA RESORT (hereinafter the “Parties”), by which the Parties agree, and the Court finds, pursuant to FRCP 26(c), that good cause exists to support the entry of a protective order over the discovery and dissemination of certain information deemed confidential by one of the Parties. This Stipulated Protective Order will expedite the disclosure of information and production of documents protected by privilege or statutes, preserve the confidentiality of such information, protect privacy interests of the Parties and non-parties, and help to avoid potential discovery disputes related to information that is designated confidential. The Court, being fully advised, hereby ORDERS as follows:

         GENERAL PROVISIONS

         1. In this action, at least one of the Parties has sought and/or is seeking discovery of Confidential Material (as defined in paragraph 5 below). This Protective Order shall apply to all documents, materials, and information that is sought by a party either from other parties to this litigation or from any third party with possession or custody of Confidential Material during discovery, including without limitation, documents produced, answers to interrogatories, responses to requests for admission, deposition testimony, and other information disclosed pursuant to the disclosure or discovery duties created by the Federal Rules of Civil Procedure. The Parties assert the disclosure of Confidential Material outside the scope of this litigation could result in significant injury to one or more of the Parties' business or privacy interests, and/or could result in significant injury to a third party's privacy interests, as well as potentially impacting or resulting in the inadvertent waiver of the attorney-client privilege. The Parties have entered into this Stipulation and request the Court enter this Protective Order for the purpose of preventing the disclosure and use of Confidential Material except as set forth herein, and to prevent the inadvertent waiver of any applicable privilege.

         2. As used in this Protective Order, “document” is defined as designated in FRCP 34(a)(1)(A). A draft or non-identical copy is a separate document within the meaning of this term.

         3. This Protective Order may be modified by the Court at any time for good cause shown following notice to all Parties and an opportunity for them to be heard.

         4. Nothing in this Protective Order shall prevent any party or other person from seeking modification of this Order, from objecting to discovery that the party or other person believes to be improper, or from filing a motion with respect to the manner in which Confidential Material shall be treated at trial. Moreover, nothing in this Protective Order shall prejudice the right of any party to contest the alleged relevancy, admissibility, or discoverability of information designated as Confidential Material or information sought in discovery.

         CONFIDENTIAL MATERIAL

         5. “Confidential Material” means those documents, personal information, trade secrets, or sensitive commercial information that the designating party believes to be protected by law, including FRCP 26, and is designated by one of the Parties in the manner provided in paragraph 15 below, the disclosure of which the designating party believes may implicate the privacy interests of Plaintiffs, Defendants, third parties and/or information contained in confidential business records and communications by the designating party or a third party with possession or custody of such information. Any information designated by a party as confidential will first be reviewed by counsel, and designation will be based on a good faith belief that the information is confidential and entitled to protection under the law, including Rule 26. The documents or information so designated shall be deemed “Confidential Material” subject to this Protective Order. Confidential Material does not include (a) any information that is in the public domain at the time of disclosure to a Receiving Party or becomes part of the public domain after its disclosure to a Receiving Party as a result of publication not involving a violation of this Order, including becoming part of the public record through trial or otherwise; and (b) any information known to the Receiving Party prior to the disclosure or obtained by the Receiving Party after the disclosure from a source who obtained the information lawfully and was not under any obligation of confidentiality to the Designating Party.

         6. Exercise of Restraint and Care in Designating Material for Protection. Each Party or Non-Party that designates information or items for protection under this Order must take care to limit any such designation to specific material that qualifies under the appropriate standards. The Designating Party must designate for protection only those pages of a document which qualify as Confidential Material, in order to avoid sweeping an entire document unjustifiably within the ambit of this Order, where only some pages contain Confidential Material. Nevertheless, where the burden of designating individual pages of a document would outweigh the benefit to full and open proceedings, the entire document may been designated confidential. Indiscriminate designations of confidentiality, however, are inconsistent with this Order. If it comes to a Designating Party's attention that information or items that it designated for protection do not qualify for protection, that Designating Party must promptly notify all other Parties that it is withdrawing the mistaken designation.

         7. Confidential Material shall not be disclosed to any person or entity not a party to this lawsuit except as expressly provided herein. Confidential Material shall only be used by the Parties in this lawsuit, including any appeal. Confidential Material shall not be disclosed to any person or entity other than the Parties to this suit, counsel who have entered an appearance in this case and their staff, judges, magistrates, law clerks and other clerical personnel of the Court before which the action is pending, and other individuals as designated in paragraph 11 of this Protective Order.

         8. Any Confidential Material produced during the course of this action shall be used solely for the purposes of this action between the Parties in this suit only, and shall not be disclosed or used for any other purpose including, but not limited to, any business, commercial, competitive, or publicity purpose. All obligations and duties arising under this Protective Order shall survive the conclusion of this action.

         9. Nothing herein shall prevent disclosure beyond the terms of this Order if this Court, after notice to all ...


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