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Slack v. Parball Newco LLC

United States District Court, D. Nevada

August 4, 2017

WILLIAM SLACK, HARRY STROCK, and EDWARD CHAMPA, on behalf of themselves, and all others similarly situated, Plaintiff,
PARBALL NEWCO LLC dba BALLY'S, PARBALL CORP., PARBALL LLC, PHWLV, LLC dba PLANET HOLLYWOOD LAS VEGAS RESORT AND CASINO, and "JOHN DOE CORPORATIONS" 1 to 50, name fictitious, actual name and number unknown, Defendants.




         This protective order will govern documents and information produced by the parties in Slack, et at. v. ParballNewco LLC, ef a/., No 2:16-cv-02324-RFB-CWH(D. Nev.). Pursuant to Federal Rule of Civil Procedure 26(c) and Local Rule of Practice 26-7, the parties may designate any documents and/or information as "confidential" consistent with the provisions of this protective order.


         A. During the course of this litigation, any party may seek to have discovery material classified as "confidential" if the designating party in good faith believes that the material contains protected, non-public confidential information under federal or state law. Such material is referred to herein as "confidential material" and the party designating the material is referred to herein as the "designating party."

         B. "Confidential material" includes all discovery produced by parties that falls within one or more of the following categories: (a) information prohibited from disclosure by statute, regulation, or court rule; (b) trade secrets or other non-public information of a proprietary, strategic, and/or competitively sensitive nature; (c) state or federal income tax information, (d) employment records of past, present, or prospective employees of Parball Newco dba Bally's, Parball Corp., Parball LLC, PHWLV LLC dba Planet Hollywood Las Vegas Resort and Casino, Paris LV Operating Co., LLC, including but not limited to: (1) compensation and benefit information; (2) work histories and performance evaluations/ratings; (3) information regarding complaints of discrimination, retaliation, or harassment and investigative files pertaining to such complaints; (4) medical and health-related information; (5) information about disciplinary action, including terminations or suspensions; and (6) personal information, including home and email addresses, dates of birth, telephone numbers, banking or other financial information, and social security numbers. The parties will comply with the local rules regarding the redaction of sensitive information.

         C. The designating party will mark each page "confidential" of documents designated as such. The designation will avoid obscuring or defacing any portion of the document. All copies of confidential discovery material will also be considered [ confidential. The designating party may designate confidential a range of documents or pages, accompanied by a writing identifying the range as confidential. If a party inadvertently fails to designate discovery material as confidential, but subsequently determines that such material should have been so designated, it will provide written notice of the confidential designation and to the extent practicable the material will be treated as confidential from the date notice is received. If a party designates material, as confidential and later determines that it should not have been so designated, it will ! provide the opposing party written notice of the removal of the designation and a copy of the material without the confidential marking.

         D. All confidential material and any portion thereof, and any information derived therefrom, will be deemed confidential and will be used only in this action including for possible resolution of the asserted claims.

         E. Material designated confidential, including copies and any information derived therefrom, will not be disclosed to anyone other than: (a) the Court and its personnel; (b) counsel of record; (c) stenographic reporters; (d) the named parties in Slack, et al. v. Parball Newco, LLC, et al\ (e) any current or former officers, directors, or employees of the parties who are needed to assist counsel; (f) and the following, provided they expressly agree to be bound by the terms of this stipulated protective order by executing the form attached as exhibit A: (i) any retained expert witness or consultant regarding this action; (ii) fact witnesses and potential witnesses at, or in preparation for, deposition, trial, or hearing in this action, or who otherwise require the information to assist counsel in this action; and (iii) outside vendors who perform photocopying, data entry, or similar clerical functions.

         Confidential material may not be disclosed to any other person or entity without prior written consent of the designating party or court order. Such disclosure should be made only to the extent reasonably necessary for effective prosecution and defense of the claims in this action and for no other purpose. Confidential materials may not be used in any other legal action, unless the designating party certifies in writing that such a use is permitted. However, nothing will preclude a recipient party from using testimony obtained in this action for impeachment purposes in other litigation.


         A. Before disclosing confidential material to persons qualified to receive it, counsel for the requesting party will secure from each such person who is not a party to this lawsuit the signed exhibit A, which provides that he or she (i) has read or has had explained to them and understands this stipulated protective order, (ii) will not divulge any confidential material except in the preparation, trial, or appeal of this action and in accordance with the terms of the stipulated protective order, and (iii) will not use the material for any other purpose.

         B. The parties' counsel will be responsible for distribution and control of confidential material who will maintain a list of all persons to whom confidential material has been disclosed and the executed written forms referenced in paragraphs I.E. and II.A. Confidential material will be copied only by counsel or personnel or outside vendors assisting counsel and only for purposes permitted by this order. For good cause shown, a designating party may request an order directing the disclosure of all persons to whom confidential material has been disclosed as well as the written assurances executed by such persons.

         C. The restrictions set forth in this protective order will not apply to any information that is or becomes public knowledge through its authorized release and not in violation of this order. If confidential material is produced by a third party that any party believes to be confidential, the parties in this litigation may designate the material as such by marking it confidential and providing the marked copy to the opposing party who will either (1) agree the material is confidential under the terms of this protective order, or (2) inform the designating party that it disagrees that the material should be governed by the terms of this protective order, but nonetheless will treat the material as confidential for at least 20 days from notice of the ...

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