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Knaack v. Knight Transportation, Inc.

United States District Court, D. Nevada

October 16, 2017

TERRI KNAACK, individually, and as Administrator of the Estate of Joseph Knaack, deceased, ANDREW KNAACK, Plaintiffs,
v.
KNIGHT TRANSPORTATION, INC.; KNIGHT REFRIGERATED, LLC; CAROL WALKER, Defendants.

          The Hon. Larry R. Hicks, Melissa J. Roose, Ashley A. Balducci, Wood, Smith, Henning & Berman LLP., Attorneys for Defendants, Knight Transportation, Inc., Knight Refrigerated, LLC & Carol Walker.

          VANNAH AND VANNAH, ASHLEY A. BALDUCCI, Attorneys for Defendants, KNIGHT TRANSPORTATION, INC., KNIGHT REFRIGERATED, LLC & CAROL WALKER.

          STIPULATED CONFIDENTIALITY AGREEMENT AND PROTECTIVE ORDER

         IT IS HEREBY STIPULATED, AGREED AND UNDERSTOOD BY Plaintiffs TERRI KNAACK, individually, and as Administrator of the Estate of Joseph Knaack, deceased, ANDREW KNAACK,, ("Plaintiffs") and Defendants KNIGHT TRANSPORTATION, INC., KNIGHT REFRIGERATED, LLC and CAROL WALKER ("Defendants"), as follows:

         1. Discovery in the above-entitled action may involve documents, photographs, video, or other information of a proprietary and non-public nature, and that the parties consider confidential or highly confidential.

         2. Pursuant to FRCP 26(c), good cause exists for the issuance of a protective order governing the handling of certain documents, photographs, video, or other information.

         3. This Order shall be applicable to and govern all confidential or highly confidential information in any form (including without limitation information contained in or on any tangible thing) produced or disclosed by or on behalf of any party to this litigation, in connection with this Case No. 3:17-cv-00172-LRH-WGC (“Action”).

         4. The following definitions shall apply:

a. “CONFIDENTIAL INFORMATION” shall mean documents, photographs, video, or other information designated as “CONFIDENTIAL” by a Producing Party, who in good faith believes the documents, photographs, video, or other information constitutes or include proprietary or non-public information that (i) is used by the party in, or pertaining to, its business; (ii) is not generally known by the general public; and (iii) the party normally would not reveal to third parties or, if disclosed, would require such third parties to maintain in confidence.
b. “HIGHLY CONFIDENTIAL INFORMATION” shall mean documents, photographs, video, or other information designated thereon as “HIGHLY CONFIDENTIAL” by a Producing Party, who in good faith believes the documents, photographs, video, or other information are particularly or especially sensitive and confidential that the Producing Party has and other discovery materials which the Producing Party considers so sensitive or confidential that added protections are warranted.
c. “Producing Party” shall mean the parties, person or entity producing CONFIDENTIAL INFORMATION or HIGHLY CONFIDENTIAL INFORMATION or giving testimony in this Action regarding or relating to CONFIDENTIAL INFORMATION or HIGHLY CONFIDENTIAL INFORMATION which has been designated as CONFIDENTIAL or HIGHLY CONFIDENTIAL subject to this Protective Order.
d. “Recipient” shall mean the party, person or entity who has agreed in writing to be subject to this Protective Order to whom the Producing Party makes available CONFIDENTIAL INFORMATION or HIGHLY CONFIDENTIAL INFORMATION. Recipient shall include those persons or entities identified in Sections 7 and 8.
e. “Disclose” shall mean the transfer or delivery to a party, person or entity of the CONFIDENTIAL INFORMATION or HIGHLY CONFIDENTIAL INFORMATION, permitting the inspection or review of the CONFIDENTIAL INFORMATION or HIGHLY CONFIDENTIAL INFORMATION, or communicating the contents of the CONFIDENTIAL INFORMATION or HIGHLY CONFIDENTIAL INFORMATION.

         5. CONFIDENTIAL INFORMATION or HIGHLY CONFIDENTIAL INFORMATION shall be used by the parties in this Action solely for the purpose of this Action, and not for any other purpose whatsoever.

         6. It is the intention of the parties that the designation of documents, photographs, video, or other information as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL” be used narrowly, and with the most limited use possible.

         7. Information designated as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL, ” and any copies, excerpts or summaries thereof, and any further information derived therefrom, shall not be revealed, disclosed or otherwise made known to persons other than those specified below or in any manner other than as specified below:

a. The Court-Any party may disclose and submit CONFIDENTIAL INFORMATION or HIGHLY CONFIDENTIAL INFORMATION to the Court, including all persons employed by the Court. Any CONFIDENTIAL INFORMATION or HIGHLY CONFIDENTIAL INFORMATION, and information derived therefrom, which are filed with the Court shall be filed in accordance with Paragraph 13 of this Stipulated Protective Order.
b. Outside Counsel-CONFIDENTIAL INFORMATION and HIGHLY CONFIDENTIAL INFORMATION may be disclosed to outside counsel for the parties in this action, including counsel's employees and outside contractors used to perform clerical functions.
c. Receiving Parties-CONFIDENTIAL INFORMATION may be disclosed (1) to in-house counsel and (2) to other employees of a Receiving Party whose participation in the prosecution or defense of the action, is necessary in the good faith assessment of counsel for the Receiving Party.
d. Expert Witnesses-CONFIDENTIAL INFORMATION and HIGHLY CONFIDENTIAL INFORMATION may be disclosed to outside experts retained to work on this action, including employees of such experts and persons providing clerical or support services. The parties agree that before any HIGHLY CONFIDENTIAL INFORMATION is provided to an expert witness, the Receiving Party must obtain written consent from the Producing Party, which consent will not be unreasonably refused. The parties agree that such persons shall agree in writing in a form substantially similar ...

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