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Cuadros v. State Farm Fire and Casualty Co.

United States District Court, D. Nevada

March 28, 2017

LUZ ELENA CUADROS, on behalf of herself and all others similarly situated, Plaintiff,

          J. Randall Jones (Nev. Bar No. 1927) Michael J. Gayan (Nev. Bar No. 11135) KEMP, JONES & COULTHARD, LLP Imanuel B. Arin, Esq. ARIN & ASSOCIATES Charles J. LaDuca Michael Flannery CUNEO GILBERT & LADUCA, LLP Melissa W. Wolchansky HALUNEN LAW Robert K. Shelquist LOCKRIDGE GRINDAL NAUEN PLLP Attorneys for Plaintiff Luz Elena Cuadros

          Riley A. Clayton (Nevada Bar No. 005260) HALL JAFFE & CLAYTON, LLP Todd A. Noteboom Jeffrey G. Mason STINSON LEONARD STREET LLP Attorneys for Defendant State Farm Fire and Casualty Company


         Plaintiff Luz Elena Cuadros (“Plaintiff”) and Defendant State Farm Fire and Casualty Company (“State Farm”) (together, the “Parties”) hereby jointly submit this Stipulated Protective Order pursuant to Federal Rule of Civil Procedure 26 and the Amended Stipulated Discovery Plan and Scheduling Order [Dkt. No. 47] § III(E) (“The parties shall enter into a stipulated protective order applicable to private, confidential, proprietary or competition-specific information.”).

         WHEREAS, the Parties agree to maintain the confidentiality of information, documents, and materials designated as “CONFIDENTIAL materials” pursuant hereto, which may contain private third-party information, including medical records, dates of birth and social security numbers, and/or constitute trade secrets or other confidential proprietary research, development, financial, or commercial information within the meaning of Fed.R.Civ.P. 26(c)(1)(G);

         WHEREAS, the Parties wish to facilitate discovery, ensure appropriate protection for any such confidential information, and ensure that production of any such documents and things shall be used only for the purposes of this case and shall not be disclosed or used in any other way; and

         WHEREAS, the Parties have agreed to jointly move this Court, pursuant to Fed.R.Civ.P. 26(c)(1), for entry of this Protective Order, and the Court having found that, in light of the medical records and confidential or trade secret nature of the competitively sensitive information that may be sought and produced in discovery, good cause exists for the entry of the following Protective Order.

         The Court finds that the Protective Order is narrowly tailored to reflect the specific confidential information requested in discovery and that good cause has been shown for entry of a confidentiality protective order pursuant to Rule 26(c)(1) of the Federal Rules of Civil Procedure, as follows:


         1. Confidential documents, information, testimony, and/or other materials designated as CONFIDENTIAL pursuant to this Order, shall be maintained in confidence by the Parties in accordance with the terms of this Order, shall be used solely for purposes of this action, and shall not be disclosed to anyone except as provided herein.

         2. All CONFIDENTIAL designations shall be made in good faith and made at the time of disclosure, production, or tender or at such other time as permitted by this Order, provided that the inadvertent failure to so designate does not constitute a waiver of such claim, and the producing Party may so designate materials as CONFIDENTIAL after such inadvertent failure, subject to the protections of this Order. Within 30 days of production, a non-producing Party may designate as CONFIDENTIAL any materials produced without a CONFIDENTIAL designation.

         3. Portions of testimony may also be designated as CONFIDENTIAL either at the time any such testimony is taken or in writing within thirty (30) days after the transcript of the testimony has been received. The court reporter for any such testimony shall be informed of this Order by the party and the court reporter shall comply with and be bound by this Order. In the event a party designates portions or all of that testimony as CONFIDENTIAL, the court reporter shall so designate on the face of the transcript that all or portions of the transcript have been designated as CONFIDENTIAL pursuant to the terms of this Order. Such CONFIDENTIAL transcripts of deposition testimony shall be treated the same and afforded the same protections as other CONFIDENTIAL materials under this Order.

         4. A non-designating Party may at any time notify a designating Party in writing or upon the record of the deposition of its objection that a portion or all of the material/information designated as CONFIDENTIAL is not entitled to such protection under the terms of this Stipulation and Order. When challenging a designation, the non-designating Party shall provide the designating Party with written notice of each challenged designation and describe the basis for each challenge. The Parties shall first attempt, in good faith, to resolve such dispute by meeting and conferring within 14 days of the date of service of the challenge. If such efforts fail to resolve the Parties' dispute, then the non-designating Party may file and serve a motion to challenge the subject confidentiality designation. The burden of persuasion in any challenge proceeding shall be on the designating Party, and the Court will view any designation as the equivalent of a request for a protective order pursuant to Fed.R.Civ.P. 26(c). Material/information designated as CONFIDENTIAL shall retain such status until such time as the Parties expressly agree otherwise in writing, the designating Party withdraws its designation in writing, or the Court orders otherwise.

         5. CONFIDENTIAL documents, information, testimony, and/or other materials (hereinafter collectively “materials”) may be made available to the Court but only upon a motion to file under seal (see paragraph 11 of this Order).

         6. The persons who may view the materials designated CONFIDENTIAL include only the Parties, their attorneys in this action, their respective clerical, secretarial and support staff, and outside consultants or experts retained by plaintiff in the prosecution of this action (subject to paragraph 7 of this Order), ...

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