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Goggin v. Enterprise Leasing Company-West, LLC

United States District Court, D. Nevada

June 18, 2017

ROBERT M. GOGGIN, Plaintiff,
v.
ENTERPRISE LEASING COMPANY-WEST, LLC, a Delaware Corporation; ABC CORPORATIONS I-X, inclusive, BLACK AND WHITE COMPANIES, and DOES 1-XX, inclusive, Defendants.

          Eric W. Swanis, Esq. (Nevada Bar No. 6840) Stephanie D. Bedker, Esq. (Nevada Bar No. 14169) Greenberg Traurig, LLP Attorneys for Defendant Enterprise Leasing Company-West, LLC

          STIPULATED PROTECTIVE ORDER AND CONFIDENTIALITY AGREEMENT

It is hereby stipulated between Plaintiff, Robert M. Goggin, by and through his counsel of record; and Defendant, Enterprise Leasing Company-West ("Defendant" or "Enterprise"), by and through its counsel of record, that the following protective order pertaining to confidential information disclosed or produced in this case is approved as to form and content, and may be entered as an Order of the Court.

         Purpose

         1. The parties recognize that preparation and trial of this action may require the discovery of certain records and other materials claimed by one or more of the parties to contain confidential business, commercial, financial, or personal information. The parties desire to litigate this action without jeopardizing their business and commercial interests, any individuals' legitimate privacy interests, or any third party interests in the confidentiality of this information, and so enter this proposed stipulated protective order ("Order").

         All documents, transcripts, or other materials subject to this Order, and all information derived therefrom (including, but not limited to, all testimony given in a deposition, declaration or otherwise, that refers, reflects, or otherwise discusses any Confidential Information, as defined below), shall not be used, directly or indirectly, by any person, for any business, commercial, or competitive purposes, or for any purpose whatsoever, other than solely in connection with this action and in accordance with the provisions of this Order.

         Confidential Designations

         2. The term "Confidential Information" shall mean and include documents, information or materials that a party reasonably believes is a formula, practice, process, design, instrument, pattern, commercial method, or compilation of information not generally known or reasonably ascertainable by others by which a business can obtain an economic advantage over competitors or customers, and are designated in good faith as "Confidential" or "Highly Confidential - Attorneys' Eyes Only" at the time of their production or disclosure in this action. The parties acknowledge that from time to time they may seek to designate as "Confidential" or "Highly Confidential - Attorneys' Eyes Only" documents that do not fall within this definition. The parties agree that these stipulations will be evaluated on a case-by-case basis and information and materials made subject to the terms of this Order once both sides confirm in writing their agreement to the same (email is sufficient).

         As a general guideline, materials designated "Confidential" shall be those confidential and sensitive matters that may be disclosed to the parties for the purpose of the litigation, but which a producing or disclosing party contends must be protected against disclosure to third parties.

         If a party has a good faith belief that documents, information, or materials are particularly sensitive, and would not be sufficiently protected as "Confidential, " that party may designate said documents, information, or materials as "Highly Confidential - Attorneys' Eyes Only."

         Absent a specific order by this Court, information once designated as "Confidential" or "Highly Confidential - Attorneys' Eyes Only" shall be used by parties solely in connection with this litigation, ; and not for any business or competitive purpose or function and such information shall not be disclosed to anyone except as provided herein. A designation of any information as "Confidential" or "Highly Confidential - Attorneys' Eyes Only" constitutes certification by the designating party that such person has reviewed the Confidential Information and has made a bona fide determination that: (1) such information is sensitive or otherwise confidential; (2) disclosure of such information without restriction would be detrimental to that party in the conduct of its business or personal affairs and cause cognizable harm; and (3) there is good cause for seeking the Court's protection.

         Manner of Designation of Confidential Information

         3. Documents, information, and materials produced in this case shall be designated in the following manner and at the following times:

(a) Documents. With respect to documents, the copy of the document when produced shall bear the clear and legible designation "Confidential" or "Highly Confidential - Attorneys Eyes Only, " as the case may be.
(b) Interrogatories or Request for Admissions. With respect to responses to interrogatories or requests for admission, the specific pages of the responses containing "Confidential" or "Highly Confidential - Attorneys Eyes Only" information shall be so marked.
(c) Depositions. In order to obtain confidential or highly confidential treatment of a deposition, the designating party must designate the specific testimony to be maintained as "Confidential" or "Highly Confidential - Attorneys Eyes Only" either on the record at the deposition or within seven (7) business days of receipt of the deposition transcript. All i deposition testimony shall be treated as "Highly Confidential - Attorneys Eyes Only" until such time as the designation deadline has passed.
(d) Documents Produced by Third Parties. The parties shall have the right to designate materials produced by third parties in this action as "Confidential" or "Highly Confidential - Attorneys Eyes Only" within seven (7) business days of the production of such materials in I this action. All such documents shall be treated as "Highly Confidential - Attorneys Eyes > Only" until such time as the designation deadline has passed.
(e) Inadvertent Disclosure. The inadvertent or unintentional disclosure of confidential business, I commercial, financial or personal information without a designation as "Confidential" or "Highly Confidential - Attorneys Eyes Only" shall not be deemed a waiver, either in whole or in part, of a party's claim that the specific information disclosed, any related information, or any information on the same or a related subject matter is confidential and subject to this Order. Upon discovery of an inadvertent or unintentional disclosure of such confidential information, counsel for the parties should, to the extent possible, cooperate to restore the confidentiality of any such information that was inadvertently or unintentionally disclosed.
(f) Documents Previously Produced. Documents previously produced in this case shall not be treated as "Confidential" or "Highly Confidential - Attorneys Eyes Only" under this Order unless so designated within seven (7) business ...

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