United States District Court, D. Nevada
BOURASSA LAW GROUP MARK J. BOURASSA, ESQ., TRENT L. RICHARDS,
ESQ. Attorneys for Plaintiff
& BIRD LLP PATRICK C. DICARLO, ESQ. Admitted Pro Hac Vice
Attorneys for Defendants
STIPULATED CONFIDENTIALITY AGREEMENT AND PROTECTIVE
FLOYD CELEY (“Plaintiff”) and Defendants HILTON
HOTELS CORPORATION N/K/A HILTON WORLDWIDE, INC. - U.S. APPEALS
COMMITTEE, HILTON HOTELS RETIREMENT BENEFIT REPLACEMENT PLAN,
AND HILTON SUPPLEMENTAL EXECUTIVE RETIREMENT PLAN,
(“Defendants”) (together, the
“Parties”), by and through their respective
counsel, have stipulated to the terms of this Confidentiality
Agreement and Protective Order.
Confidentiality Agreement and Protective Order is designed to
preserve the confidentiality of information contained in
documents produced pursuant to the terms of this Protective
Order and certain testimony given by witnesses in this case.
expedite the flow of discovery material, facilitate the
prompt resolution of disputes over confidentiality, and
adequately protect material entitled to be kept confidential,
it is, by agreement of the Parties and pursuant to the
Court's authority under the Federal Rules of Civil
Procedure, STIPULATED and ORDERED that:
OF CONFIDENTIALITY AGREEMENT
Parties hereby stipulate and agree that the production of
documents in the above-entitled action, while not necessarily
confidential between the Parties to this litigation, are
confidential as to any other party not part of this
litigation. The Parties therefore agree to produce documents
in their “raw form” to each other, that being
unredacted documents as to an individual's
social-security number, taxpayer-identification number, or
birth date, the name of an individual known to be a minor, or
a financial-account number.
Parties further stipulate and agree that each Party will take
all steps necessary to appropriately protect and redact any
sensitive information in accordance with Fed.R.Civ.P. 5.2 and
Local Rule LR IC 6-1 prior to disseminating the documents,
filing the documents with the Court, or utilizing the
documents in this litigation.
Party utilizing any document produced in this litigation must
refrain from including- or must partially redact, where
inclusion is necessary-the following personal-data
identifiers from all documents filed with the court,
including exhibits, whether filed electronically or in paper,
unless the court orders otherwise:
(1) Social Security Numbers. If an individual's Social
Security number must be included, only the last four digits
of that number should be used.
(2) Names of Minor Children. If the involvement of a minor
child must be mentioned, only the initials of that child
should be used.
(3) Dates of Birth. If an individual's date of birth must
be included, only the year should be used.
(4) Financial Account Numbers. If financial account numbers
must be included, only the last four digits of these ...