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Kennedy v. University Medical Center

United States District Court, D. Nevada

April 28, 2017

PATRICIA KENNEDY, an individual, Plaintiff,
v.
UNIVERSITY MEDICAL CENTER a.k.a UNIVERSITY MEDICAL CENTER OF SOUTHERN NEVADA a.k.a. UMC, a political subdivision of Nevada; DOES I-V; ROES VI-X, Defendants.

          KRISTINA MILETOVIC, ESQ. Nevada State Bar No. 14089 RNOLD WEINSTOCK, ESQ. Nevada State Bar No. 810 SCOTT C. DORMAN, ESQ. Nevada State Bar No. 13108 Attorneys for Plaintiff.

          JEFFREY I. PITEGOFF, ESQ. Nevada Bar No. 005458 DANIEL S. CEREGHINO, ESQ. Nevada Bar No. 011534 MORRIS, SULLIVAN, LEMKUL & PITEGOFF Attorneys for Defendant UMC.

          STIPULATED PROTECTIVE ORDER

         Plaintiff, PATRICIA KENNEDY (“Plaintiff”), by and through the Law Office of Dan M. Winder, P.C. and Defendant, UNIVERSITY MEDICAL CNETER OF SOUTHERN NEVADA (“Defendant), by and through the law firm of Morris, Sullivan, Lemkul & Pitegoff, LLP, hereby stipulate and agree as follows:

         1. PURPOSES AND LIMITATIONS

         Disclosure and discovery activity in this action are likely to involve production of confidential, proprietary, or private information for which special protection from public disclosure and from use for any purpose other than prosecuting this litigation is warranted. Accordingly, the parties hereby stipulate to and petition the court to enter the following Stipulated Protective Order. The parties acknowledge that this Order does not confer blanket protections on all disclosures or responses to discovery and that the protection it affords extends only to the limited disclosures or responses to discovery and that the protection it affords extends only to the limited information or items that are entitled under the applicable legal principles to treatment as confidential.

         2. DEFINITIONS

         2.1 Party: any party to this action, including all of its officers, directors, employees, consultants, retained experts, carrier representatives and outside counsel (and their support staff).

         2.2 Disclosure or Discovery Material: all items or information, regardless of the medium or manner generated, stored, or maintained (including, among other things, testimony, transcripts, or tangible things) that are produced or generated in disclosures or responses to discovery in this matter.

         2.3 “Confidential” Information or Items: information (regardless of how generated, stored or maintained) or tangible things that qualify for protection under standards developed under F.R.Civ.P. 26(c).

         2.5 Receiving Party: a Party that receives Disclosure or Discovery or Discovery Material from a Producing Party.

         2.6 Producing Party: a Party or non-party that produces Disclosure or Discovery Material in this action.

         2.7 Designating Party: a Party or non-party that designates information or items that it produces in disclosures or in responses to discovery as “Confidential.”

         2.8 Protected Material: any Disclosure or Discovery Material that is designated as "Confidential."

         2.9 Outside Counsel: attorneys who are not employees of a Party but who are retained to represent or advise a Party in this action, including coverage counsel and/or a carrier's claims counsel.

         2.10 House Counsel: attorneys who are employees of a Party.

         2.11 Counsel (without qualifier): Outside Counsel and House Counsel (as well as their support staffs).

         2.12 Expert: a person with specialized knowledge or experience in a matter pertinent to the litigation who has been retained by a Party or its counsel to serve as an expert witness or as a consultant in this action and who is not a past or a current employee of a Party or of a competitor of a Party's and who, at the time of retention, is not anticipated to become an employee of a Party or a competitor of a Party's. This definition includes a professional jury or trial consultant retained in connection with this litigation.

         2.13 Professional Vendors: persons or entities that provide litigation support services (e.g., photocopying; videotaping; translating; preparing exhibits or demonstrations; organizing, storing, retrieving data in any form or medium; etc.) and their employees and subcontractors.

         3. SCOPE

         The protections conferred by this Stipulation and Order cover not only Protected Material (as defined above), but also any information copied or extracted therefrom, as well as all copies, excerpts, summaries, or compilations thereof, plus testimony, conversations, or presentations by parties or ...


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