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Boyle v. Hilton Hotels Corporation

United States District Court, D. Nevada

April 28, 2017

MICHAEL BOYLE; WILLIAM BIGELOW; DARRYL DAUENHAUER; HORST DZIURA; GARY GREGG; WILLIAM HARLAND; PAUL HOUDAYER; CHRISTOPHER NORDLING; WILLIAM SHERLOCK; AND FERENC SZONY, Plaintiffs,
v.
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.

          MARK J. BOURASSA, ESQ. TRENT L. RICHARDS, ESQ. Attorney for Plaintiffs

          PATRICK C. DICARLO, ESQ. Attorneys for Defendants

          STIPULATED CONFIDENTIALITY AGREEMENT AND PROTECTIVE ORDER

         Plaintiffs MICHAEL BOYLE; WILLIAM BIGELOW, DARRYL DAUENHAUER, HORST DZIURA, GARY GREGG, WILLIAM HARLAND, PAUL HOUDAYER, CHRISTOPHER NORDLING, WILLIAM SHERLOCK, AND FERENC SZONY (“Plaintiffs”) and Defendants HILTON HOTELS CORPORATION N/K/A HILTON WORLDWIDE, INC.[1] - 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.

         This 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.

         To 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:

         TERMS OF CONFIDENTIALITY AGREEMENT

         The 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.

         The 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.

The 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.
Financial Account Numbers. If financial account numbers must be included, only the last four digits of these ...

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