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E&R Venture Partners, LLC v. Park Central Plaza 32, LLC

United States District Court, D. Nevada

May 17, 2017

E&R VENTURE PARTNERS, LLC, a California limited liability company, Plaintiff,
v.
PARK CENTRAL PLAZA 32, LLC, a revoked Nevada limited liability company; and DOES I-X, Defendants.

          PETERSON BAKER, PLLC TAMARA BEATTY PETERSON, ESQ. Nevada Bar No. 5218 NIKKI L. BAKER, ESQ. Nevada Bar No. 6562 BENJAMIN K. REITZ, ESQ. Nevada Bar No. 13233 Attorneys for Plaintiff E&R Venture Partners, LLC.

          JK LEGAL & CONSULTING, LLC JARED B. KAHN, ESQ. Nevada Bar No. 12603 Attorneys for Defendant Park Central Plaza 32, LLC.

          [PROPOSED] CONFIDENTIALITY AND PROTECTIVE ORDER

         This Confidentiality and Protective Order (this "Protective Order") is stipulated to by and between Plaintiff E&R Venture Partners, LLC ("Plaintiff") and Defendant Park Central Plaza 32, LLC ("Defendant"') (each referred to herein as a "Party" and collectively, the "Parties").

         WHEREAS, Defendant entered into a confidential settlement agreement with Nevada State Bank (the "NSB Settlement"') in the action styled Park Central Plaza 32, LLC v. Nevada State Bank, Eighth Judicial District Court, Case No. A-13-677612-B and Supreme Court of Nevada Docket No. 67805.

         WHEREAS, on April 5, 2017, Plaintiff filed a "Motion to Compel Defendant to Disclose Information and Documentation Concerning the NSB Settlement" [ECF No. 25] (the "Motion to Compel").

         WHEREAS, on May 2, 2017, the Court entered an Order [ECF No. 36] granting the Motion to Compel, denying Defendant's Motion for Protective Order [ECF No. 29], and directing Defendant to produce the NSB Settlement document and respond to Plaintiffs written discovery concerning the NSB Settlement, subject to a protective order as described in the Order.

         NOW THEREFORE, the Parties, by and through their undersigned counsel, hereby stipulate and agree, subject to the Court's approval, as follows:

         I. DEFINITIONS

         The following definitions apply to this Protective Order:

         1. Party. Any Party to this action, including all of its officers, directors, employees, consultants, Experts (as defined below), and Outside Counsel (as defined below).

         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.

         3. Confidential Information or Items.

         Information (regardless of how generated, stored or maintained) or tangible things that the Designating Party has a good-faith basis for believing contains information that: (a) is confidential under federal or state law or regulations; or (b) contains criminal history information, personal information regarding individuals including Social Security Numbers, dates of birth and information which a person would have a reasonable expectation of privacy, and other sensitive financial or professional information that is generally unavailable to the public and that, if made available to the public, may be injurious to that Party's personal, financial, or professional interests. Confidential Information shall include the document memorializing the NSB Settlement and Defendant's answers and responses to written discovery and deposition inquiries and responses concerning the same. Further, Confidential Information shall also include any information protected from disclosure under Donrey v. Bradshaw, 106 Nev. 630 (1990), or an official or executive information privilege. Confidential Information shall also include employee information, employee medical information, and employee disciplinary action, including any internal investigation concerning employee actions.

         4. Receiving Party.

         A Party that receives Disclosure or Discovery Material or Confidential Information from a Producing Party.

         5. Producing Party.

         A Party or third-party that produces Disclosure or Discovery Material or Confidential Information in this action.

         6. Designating Party.

         A Party or third-party that designates information or items that it produces in disclosures or in responses to discovery as "Confidential".

         7. Protected Material. Any Disclosure or Discovery Material or Confidential Information that is designated as "Confidential." 8. Outside Counsel. Attorneys who are not employees of a Party but who are retained to represent or advise a Party in this action.

         9. In-House Counsel.

         Attorneys who are employees of a Party.

         10. Counsel (without qualifier).

         Outside Counsel and In-House Counsel (as well as their support staff).

         11. Expert.

         A person with specialized knowledge or experience in a matter pertinent to the litigation retained by a Party or its Counsel to serve as an expert witness or as a consultant in this action. This definition includes, but is not limited to, a professional jury or trial consultant retained in connection with this action.

         12. Professional Vendor.

         Person or entity that provides litigation support services (e.g., photocopying, videotaping, translating, preparing exhibits or demonstrations, organizing, storing, retrieving data in any form or medium, etc.) and its employees and subcontractors.

         13. The use of the singular form of any word includes the ...


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