United States District Court, D. Nevada
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
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:
PURPOSES AND LIMITATIONS
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.
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).
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
“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).
Receiving Party: a Party that receives Disclosure or
Discovery or Discovery Material from a Producing Party.
Producing Party: a Party or non-party that produces
Disclosure or Discovery Material in this action.
Designating Party: a Party or non-party that
designates information or items that it produces in
disclosures or in responses to discovery as
Protected Material: any Disclosure or Discovery
Material that is designated as "Confidential."
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.
House Counsel: attorneys who are employees of a
Counsel (without qualifier): Outside Counsel and
House Counsel (as well as their support staffs).
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
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.
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