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Bobo v. Clark County Collection Service, LLC

United States District Court, D. Nevada

June 26, 2017

JAMILAH BOBO, Plaintiff,
v.
CLARK COUNTY COLLECTION SERVICE, LLC, Defendant.

          Michael Kind, Esq. KAZEROUNI LAW GROUP, APC Attorneys for Jamilah Bobo.

          Patrick J. Reilly, Esq. Susan M. Schwartz, Esq. Holland & Hart LLP Attorneys for Clark County Collection Service, LLC.

          STIPULATED CONFIDENTIALITY AGREEMENT AND PROTECTIVE ORDER

         Claimant Jamilah Bobo (“Bobo”) and Defendant Clark County Collection Service, LLC (“CCCS”) hereby stipulate and agree as follows:

         1. Confidential Information. In providing or revealing discovery materials, any party may designate as “CONFIDENTIAL” the whole or any part of discovery material which constitutes trade secrets, know-how, proprietary data, marketing information, contracts, financial information, and/or similar commercially sensitive business information or data which the designating party in good faith believes in fact is confidential or that unprotected disclosure might result in economic or competitive injury, and which is not publicly known and cannot be ascertained from an inspection of publicly available documents, materials, or devices. A party may also designate as “CONFIDENTIAL” compilations of publicly available discovery materials, which would not be known publicly in a compiled form. A party may add as “CONFIDENTIAL” any documents containing personal information, such as phone numbers, addresses and social security numbers.

         2. Designation of Confidential Information. If a party (the “Producing Party”) in this action determines that any of its documents or things or responses produced in the course of discovery in this action should be designated as provided in Paragraph 1 and, therefore constitute “Confidential Information, ” it shall advise the other party (“Receiving Party”) who had received such Confidential Information of this fact, and all copies of such document or things or responses or portions thereof deemed to be confidential shall be marked “CONFIDENTIAL” at the expense of the Producing Party and treated as confidential by all parties.

         3. Designation of Highly Confidential Information A Producing Party may designate as “HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY” documents, items or information that the party believes in good faith contains material constituting a trade secret, or confidential research, development, personal, commercial, or financial information, the disclosure of which is reasonably likely to result in detriment to the Producing Party or the subject of the information disclosed. In the event that information designated as “CONFIDENTIAL” is later desired by a party to come within the “HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY” category, that party may so designate the information by notice to all parties.

         4. Use of Confidential Information and Highly Confidential Information. All Confidential Information and Highly Confidential Information designated or marked as provided shall be used by the Receiving Party solely for the purposes of this lawsuit, and shall not be disclosed to anyone other than those persons identified herein in Paragraph 6 for Confidential Information and in Paragraph 7 for Highly Confidential Information, and shall be handled in this manner until such designation is removed by the Producing Party or by order of the Court or Arbitrator, as applicable. Such Confidential Information shall not be used by any Receiving Party or other person granted access under this Stipulated Confidentiality Agreement and Protective Order (“Protective Order” or “Order”) for any purpose, including, but not limited to, a business or competitive purpose. Nothing shall preclude the Producing Party from using its own Confidential Information or giving others to use their Confidential Documents.

         Documents, deposition testimony, or answers to interrogatories stamped “Confidential” or “Highly Confidential, ” or copies or extracts therefrom, and compilations and summaries thereof, and the information therein, may be given, shown, made available to, or communicated in any way only to those parties or other persons who agree in advance to abide by this Protective Order and to whom it is necessary that the material be shown for purposes of this litigation. Once the Order is entered by the Court, the producing party shall have thirty (30) days to designate as Confidential or Highly Confidential any documents previously produced, which it can do by stamping “Confidential” or “Highly Confidential - Attorneys' Eyes Only” on the document, or informing the other parties of the bates-numbers of the documents it wants to designate confidential.

         5. Use of Confidential Information and Highly Confidential Information in Depositions. Any party shall have the right to use Confidential Information during depositions, provided that no third parties are present during such depositions. Counsel for any party shall have the right to use Highly Confidential Information during depositions, provided that no party or any third party to whom such Highly Confidential Information is not permitted to be disclosed herein is present during such depositions. At any deposition session, upon inquiry with regard to the content of a document marked “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY” whenever counsel for a party deems that the answer to the question may result in the disclosure of Confidential Information or Highly Confidential Information, or whenever counsel for a party deems that the answer to any question has resulted in the disclosure of Confidential Information or Highly Confidential Information, the deposition (or portions) may be designated by the affected party as containing Confidential Information or Highly Confidential Information subject to the provisions of this Order. When such designation has been made, the testimony or the transcript of such testimony shall be disclosed only to those parties described in Paragraph 6 for Confidential Information and in Paragraph 7 for Highly Confidential Information, and the information contained shall be used only as specified in this Protective Order.

         Counsel for the person whose Confidential Information or Highly Confidential Information is involved may also request that all persons not qualified under Paragraph 6 or Paragraph 7 of this Protective Order to have access to the Confidential Information or Highly Confidential Information leave the deposition room during the confidential portion of the deposition. Failure of such other persons to comply with a request to leave the deposition shall constitute substantial justification for counsel to advise the witness that the witness need not answer the question seeking the revelation of Confidential Information or Highly Confidential Information. Moreover, all originals and copies of deposition transcripts that contain Confidential Information or Highly Confidential Information shall be prominently marked “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY” on the cover thereof and, if and when filed with the Court, the portions of such transcript so designated shall be filed under seal. Counsel must designate portions of a deposition transcript as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL - ATTORNEYS' EYES ONLY” within thirty (30) days of receiving the transcript. Designations may be made by letter to counsel of record or on the record during the deposition. Portions of deposition transcripts so designated shall be treated as Confidential Information by the parties as set forth herein. During the thirty (30) day period, the entire transcript shall be treated as Confidential Information (or Highly Confidential Information if any document marked as Highly Confidential was used or if counsel indicates that any response to a question contained Highly Confidential Information during such deposition). If no confidential designations are made within the thirty (30) day period, the entire transcript shall be considered non-confidential.

         6. Disclosure of Confidential Information. Confidential Information produced pursuant to this Order may be disclosed or made available only to the Court, and to the persons designated below:

a. Retained counsel and in-house counsel for a party (including attorneys associated with the law firm of counsel, the paralegal, clerical, and secretarial staff employed by such counsel, and any data processing personnel retained by such counsel to assist in these proceedings);
b. A party, or officers, directors, and employees of a party deemed necessary by counsel to aid in the prosecution, defense, or settlement of this action;
c. Outside experts or consultants (together with their clerical staff) retained by such counsel to assist in the prosecution, ...

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