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Westgate LVH, LLC v. Trustees of Nevada Resort Association

United States District Court, D. Nevada

October 11, 2017

WESTGATE LVH, LLC, Plaintiff,
v.
TRUSTEES OF THE NEVADA RESOIRT ASSOCIATION, INTERNATIONAL ALLIANCE OF THEATRICAL STAGE EMPLOYEES I.A.T.S.E. LOCAL 720 PENSION TRUST, Defendants.

          VINCENT J. AIELLO, ESQ., Greenspoon Marder, P.A., ANTHONY L. MARTIN, ESQ., Russell S. Buhite, Russell S. Buhite OGLETREE DEAKINS NASH SMOAK & STEWART, P.C., Attorneys for Plaintiff Westgate LVH, LLC.

          BROWNSTEIN HYATT FARBER SCHRECK, Adam P. Segal, Esq., Christopher M. Humes, Esq., Attorney for Defendants.

          STIPULATED PROTECTIVE ORDER PURSUANT TO FRCP 26(A)1

          NANCY J. KOPPE UNITED STATES MAGISTRATE JUDGE.

         Plaintiff, WESTGATE LVH, LLC (“Westgate”), by and through their attorneys of record, Vincent J. Aiello, Esq., of GREENSPOON MARDER, P.A. (“Plaintiff”), and TRUSTEES OF THE NEVADA RESOIRT ASSOCIATION, INTERNATIONAL ALLIANCE OF THEATRICAL STAGE EMPLOYEES (I.A.T.S.E.) LOCAL 720 PENSION TRUST (collectively referred to as “Defendants”) hereby request the Court enter the following Stipulated Protective Order. This Stipulation is brought pursuant to and in compliance with Local Rule 7-1.

         The parties are expected to request confidential, non-public information and documents from each other, including but not limited to, attorney-client privileged information, proprietary information, trade-secrets, business operations, account and financial records, non-public business records, and other information and documents regarding certain individuals, who are not, and are not expected to be, individual parties to this action. The parties consider this information and these documents to be private, confidential and privileged from any disclosure.

         Discovery in this case will most likely require the production of documents, the answering of Interrogatories and Requests for Admission, and the taking of oral and/or written depositions, during which the aforementioned attorney client privileged information, proprietary, trade secret, confidential and/or private information and documents of the parties will be exchanged and disclosed. To facilitate the prompt resolution of disputes over confidentiality and to adequately protect material entitled to remain privileged and be kept confidential, the parties agree to limit the disclosure and use of attorney client privileged information, confidential, and private information and documents pursuant to this Stipulated Protective Order entered in the above captioned-action on the following terms:

         DEFINITIONS

         The following definitions shall apply to this Stipulated Protective Order:

         A. The “Action” shall refer to in the instant litigation originally filed in the United States District Court for the District of Nevada, Case No.: 2:17-cv-01731-RFB-NJK, and any appeal thereof through final determination. The “Action” does not refer to any “related case” unless ordered by this Court.

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

         C. “Party” or “Parties” shall mean the Plaintiff and Defendants in this Action, and any other person that may become a named Party to the Action.

         D. “Confidential” information means any information or material that is designated as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL - ATTORNEY CLIENT PRIVILEGED” or “OUTSIDE ATTORNEYS' EYES ONLY” as provided for in this Order. Confidential information shall be defined as such documents, deposition testimony or other information disclosed during discovery in the Action which the Producing Party or another Party reasonably and in good faith contends contains information that should be protected from disclosure pursuant to this Stipulated 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 Stipulated Protective Order, no Party waives the right to challenge any other Party's designation of any information or document as Confidential. Confidential information may include, but is not limited to, documents, deposition and other testimony, and interrogatory answers as they relate to any non-public financial, trade and/or proprietary information concerning Plaintiff, Defendants and any and all of their affiliates, predecessors, successors, assigns, agents, contractors and attorneys; documents relating to Defendants' clients, applicants, and prospective clients and applicants (including client complaints and contact information), budgetary information, business plans, strategy and marketing, salary information, pricing information, and agreements with employees and non-parties.

         E. “Legend” as used herein shall mean a stamp or similar insignia stating “CONFIDENTIAL” “HIGHLY CONFIDENTIAL - ATTORNEY CLIENT PRIVILEGED” or “OUTSIDE ATTORNEYS' EYES ONLY”.

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

         G. “Outside Counsel” means (i) outside attorneys who appear on the pleadings or docket for the Action as counsel-of-record for a Party, (ii) partners and associates of the law firms of such attorneys to whom it is reasonably necessary to disclose Confidential information for the Action and who receive Confidential information.

         H. “Outside Attorneys' Eyes Only” shall mean only to be reviewed by Outside Counsel.

         I. DESIGNATION OF INFORMATION AND DOCUMENTS

         When any document or thing produced under this Stipulated Protective Order is designated as CONFIDENTIAL, HIGHLY CONFIDENTIAL - ATTORNEY CLIENT PRIVILEGED or OUTSIDE ATTORNEYS' EYES ONLY, 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.

         A Producing Party may designate documents, information or material as CONFIDENTIAL, HIGHLY CONFIDENTIAL - ATTORNEY CLIENT PRIVILEGED or OUTSIDE ATTORNEYS' EYES ONLY, only upon a good faith belief that the documents, information, or material ...


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