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Arrington v. Franklin Collection Service, Inc.

United States District Court, D. Nevada

October 23, 2017

SARAH ARRINGTON, Plaintiff,
v.
FRANKLIN COLLECTION SERVICE, INC., a Mississippi corporation, Defendant.

          ROBERT S. LARSEN, ESQ., WING YAN WONG, ESQ., GORDON REES SCULLY MANSUKHANI, LLP., Attorneys for Franklin Collection Service, Inc.

          [PROPOSED] STIPULATED PROTECTIVE ORDER

          PEGGY A. LEEN UNITED STATES MAGISTRATE JUDGE.

         IT IS HEREBY STIPULATED by and between Plaintiff Sarah Arrington and Defendant Franklin Collection Service, Inc. (collectively, the “parties”), through their respective counsel of record, stipulate that this [Proposed] Stipulated Protective Order (“Protective Order”) shall govern all information and documents disclosed or produced in this case, including information and documents that may be disclosed or produced before this Protective Order is entered by the Court.

         WHEREAS the parties to this case may be required to disclose to the other certain sensitive, personal, confidential and/or proprietary information and documents relating to the subject matter of this litigation, the unauthorized use or disclosure of which is likely to cause harm to the party producing such information or contravene an obligation of confidentiality to a third person or to a court.

         Accordingly, the parties hereby stipulate to and petition the Court to enter the Protective Order, pursuant to Fed.R.Civ.P. 26(c). The parties acknowledge that this Protective Order does not confer blanket protections on all disclosures or responses to discovery and that the protection it affords extends only to the limited information or items that are entitled to treatment as confidential under applicable state or federal law. The parties further acknowledge that this Protective Order creates no entitlement to file confidential information under seal; the parties shall follow the applicable rules when seeking permission from the Court to file material under seal. The parties respectfully request that this Court enter the [Proposed] Stipulated Protective Order on the following terms:

         I. DEFINITIONS

         The following Definitions shall apply in this Order:

         A. The term “Confidential Information” will mean and include information contained or disclosed in any materials, including documents, portions of documents, answers to interrogatories, responses to requests for admissions, trial testimony, deposition testimony, and transcripts of trial testimony and depositions, including data, summaries, and compilations derived therefrom that is deemed to be Confidential Information by any party to which it belongs.

         B. The term “Materials” will include, but is not be limited to: documents; correspondence; memoranda; financial information; email; specifications; marketing plans; marketing budgets; customer information; materials that identify customers or potential customers; price lists or schedules or other matter identifying pricing; minutes; letters; statements; cancelled checks; contracts; invoices; drafts; books of account; worksheets; forecasts; notes of conversations; desk diaries; appointment books; expense accounts; recordings; photographs; motion pictures; sketches; drawings; notes of discussions with third parties; other notes; business reports; instructions; disclosures; other writings; records of website development; and internet archives.

         C. The term “Counsel” will mean outside counsel of record, and other attorneys, paralegals, secretaries, and other support staff employed in the following law firms: Gordon & Rees, LLP and Gesund & Pailet, LLC.

         II. LIMITATIONS ON DISCLOSURE OF CONFIDENTIAL INFORMATION

         The following provisions shall apply in this litigation:

         1. Each party to this litigation that produces or discloses any Materials, answers to interrogatories, responses to requests for admission, trial testimony, deposition testimony, and transcripts of trial testimony and depositions, or information that the producing party believes should be subject to this Protective Order may designate the same as “CONFIDENTIAL” or “CONFIDENTIAL - FOR COUNSEL ONLY.”

         (a) Designation as “CONFIDENTIAL”: Any party may designate information as “CONFIDENTIAL” only if, in the good faith belief of such party and its Counsel, the unrestricted disclosure of such information could be harmful to the business or operations of such party.

         (b) Designation as “CONFIDENTIAL - FOR COUNSEL ONLY”: Any party may designate information as “CONFIDENTIAL - FOR COUNSEL ONLY” only if, in the good faith belief of such party and its Counsel, the information is among that considered to be most sensitive by the party, including but not limited to trade secret or other confidential research, development, financial, customer related data or other commercial information.

         2. In the event the producing party elects to produce Materials for inspection, no marking need be made by the producing party in advance of the initial inspection. For purposes of the initial inspection, all Materials produced will be considered as “CONFIDENTIAL - FOR COUNSEL ONLY, ” and must be treated as such pursuant to the terms of this Order. Thereafter, upon selection of specified Materials for copying by the inspecting party, the producing party must, within a reasonable time prior to producing those Materials to the inspecting party, mark the copies of those Materials that contain Confidential Information with the appropriate confidentiality marking.

         3. Whenever a deposition taken on behalf of any party involves the disclosure of Confidential Information of any party:

         (a) the deposition or portions of the deposition must be designated as containing Confidential Information subject to the provisions of this Order; such designation must be made on the record whenever possible, but a party may designate portions of depositions as containing Confidential Information after transcription of the proceedings; a party will have until thirty (30) days after receipt of the deposition transcript to inform the other party or parties to the action of the portions of the transcript to be designated “CONFIDENTIAL” or “CONFIDENTIAL - FOR COUNSEL ONLY.” Until thirty (30) days after receipt of the transcribed testimony, such testimony shall be treated by the parties as Confidential Information.

         (b) the disclosing party will have the right to exclude from attendance at the deposition, during such time as the Confidential Information is to be disclosed, any person other than the deponent, Counsel (including their staff and associates), the court reporter, and the person(s) agreed upon pursuant to paragraph 8, below; and

         (c) The originals of the deposition transcripts and all copies of the deposition must bear the legend “CONFIDENTIAL” or “CONFIDENTIAL - FOR COUNSEL ONLY, ” as appropriate, and the original or any copy ultimately presented to a court for filing must not be filed unless it can be accomplished under seal, identified as ...


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