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Benmelech v. Eldorado Resorts Corp.

United States District Court, D. Nevada

August 1, 2017

CHAIM BENMELECH, Plaintiff,
v.
ELDORADO RESORTS CORPORATION, a Florida Corporation; MICHAEL MARRS; KRISTEN BECK; DOMINIC TALEGHANI; and DOES 1-50, inclusive, Defendants.

          WATKINS & LETOFSKY, LLP, Daniel R. Watkins, Brian S. Letofsky, Attorneys for Plaintiff Chaim Benmelech.

          OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C., Anthony L. Martin, Jill Garcia, Amy L. Howard, Attorneys for Defendant Eldorado Resorts Corporation.

          STIPULATED PROTECTIVE ORDER GOVERNING THE CONFIDENTIALITY OF INFORMATION AND DOCUMENTS

         Pursuant to Fed.R.Civ.P. 26(c), LR IA 6-2, and LR 7-1, Defendant Eldorado Resorts Corporation (“Eldorado”) and Plaintiff Chaim Benmelech (“Plaintiff”), hereby stipulate and agree as follows:

         Plaintiff is expected to and has requested confidential, non-public, trade secret, financial, medical and/or proprietary information and documents from Eldorado related to its business operations, including, but not limited to, sales reports, information that may contain customer information, including customer names, addresses, and financial information, medical information and other information that may include disclosure of information related to Eldorado employees, who are not, and are not expected to be, parties to this matter. Eldorado considers this information and these documents to be private and confidential.

         Discovery in this case will require the production of documents, inspection of tangible things, the answering of Interrogatories and Requests to Admit, and the taking of oral and/or written depositions, during which the aforementioned proprietary, trade secret, financial, medical, confidential and/or private information and documents of the parties will be exchanged and disclosed. To expedite the flow of discovery, facilitate the prompt resolution of disputes over confidentiality, and to protect adequately material entitled to be kept confidential, the parties agree to limit the disclosure and use of proprietary, confidential, and private information and documents as stipulated, pursuant to this Protective Order on the following terms:

         I. DEFINITIONS

         The following definitions shall apply to this Protective Order:

         A. “Producing Party” shall mean any person or entity producing documents, information or other materials in the instant matter, including any Party to the instant matter or any third parties.

         B. “Party” shall mean the Plaintiff and Defendant, and any other person that may become a named Party to the instant matter.

         C. “Confidential” information shall be defined as such documents, deposition testimony or other information disclosed during discovery which the Producing Party or another Party reasonably and in good faith contends contains information that should be protected from disclosure pursuant to this Protective Order. Any Party may designate any information or documents as confidential in the reasonable exercise of such Party's sole discretion; provided, however, by agreeing to this Protective Order, no Party waives the right to challenge any other Party's designation of any information or document as confidential.

         D. “Legend” as used herein shall mean a stamp or similar insignia stating confidential.

         E. When reference is made in this Protective Order to any document or Party, the singular shall include the plural, and plural shall include the singular.

         F. “Attorneys' Eyes Only” shall mean only to be reviewed by counsel of record.

         II. DESIGNATION OF INFORMATION AND DOCUMENTS

         A. When any document or things produced under this Protective Order are designated as confidential, a Legend shall be affixed to the first page and all pages containing information for which the Producing Party seeks protection. When information produced in answer to an Interrogatory, or response to a Request for Production or Request for Admission is designated as confidential, the response or answer shall be preceded with the appropriate designation.

         B. Some documents being produced by both Plaintiff and Defendant may contain social security numbers of Plaintiff and/or Eldorado's employees. Without need of any designation, social security numbers will be deemed to be confidential. In the event a document is produced without the redaction of a social security number, any Party seeking to use the document will make every effort to redact the social security number before its use in a deposition, court proceeding or court filing.

         C. The initial failure to designate information or documents as confidential in accordance with this Protective Order shall not preclude the Producing Party from, at a later date, designating any information or documents as confidential. The Producing Party may, by written notice to counsel of record for the receiving Party, designate previously produced information or documents as confidential, which it had inadvertently failed to designate. Upon receipt of such notice, the receiving Party shall promptly mark its copies of the information or documents so designated, and shall thereafter, treat the information and documents as if it had been designated confidential and shall restrict the disclosure or use of the information or documents in accordance with this Protective Order. If the information or documents have previously been disclosed to non-parties, the Parties shall take reasonable steps to obtain all ...


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