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Guzman v. Pep Boys Manny Moe & Jack

United States District Court, D. Nevada

November 15, 2017

MARIE ANTIONETTE GUZMAN, as Administrator of the Wrongful Death Estates of RAYMOND GUZMAN and MARY GUZMAN, Plaintiff,
v.
THE PEP BOYS MANNY MOE & JACK, a Pennsylvania corporation; COOPER TIRE & RUBBER COMPANY, a Delaware corporation; GENERAL MOTORS COMPANY, LLC, a Delaware corporation; ROE COMPONENT PART MANUFACTURER; ROE CORPORATIONS I through X, inclusive, Defendants.

          David J. Martin, Esq. Richaid Harris Law Firm, Attorneys for Plaintiff

          Greg W. Marsh, Esq. Law Offices of Greg W. Marsh, Attorney for General Motors LLC

          Paul A. Shpirt, Esq. Lewis Brisbois 6385 South Rainbow Blvd., Suite Attorneys for The Pep Boys Manny Moe & Jack

          J. Christopher Jorgensen, Esq. Lewis Roca Rothgerber Christie LLP, Attorneys for Cooper Tire & Rubber Company

          PROTECTIVE ORDER OF CONFIDENTIALITY

         1. "Confidential Material."

         As used in this Protective Order of Confidentiality, confidential material shall refer to records and/or things of any party from whom production is requested in this lawsuit (hereinafter "Producing Party"), which the Producing Party contends in good faith are protected as trade secrets, confidential commercial information, medical information, or financial information pursuant to state and/or federal law, and are not of public record. All confidential material is the exclusive, inalienable property of the Producing Party.

         2. "Records."

         As used in this Protective Order of Confidentiality, records shall mean information that is in document form, inscribed or otherwise recorded on a tangible medium, or that is stored in an electronic or other medium and is retrievable in perceivable form. Records includes both electronic records and printed, typewritten, and other tangible records.

         3. Scope.

         This Protective Order of Confidentiality shall govern confidential material produced or disclosed by any Producing Party in response to formal or informal discovery conducted in this lawsuit. Nothing in this Protective Order of Confidentiality shall be deemed to preclude the Producing Party's right to: (a) oppose discovery on grounds not addressed under the terms of this Protective Order of Confidentiality, or (b) object on any ground to the admission of any confidential material into evidence at trial. Further, nothing contained in this Protective Order of Confidentiality shall prejudice the right of any party to contest the alleged relevancy, admissibility, or discoverability of the confidential material sought.

         4. Designation of Confidential Material.

         Any Producing Party may designate as confidential material all or any portion of records and/or things it produces formally or informally to other parties to this litigation, their counsel, and/or any authorized person (as defined below) to whom they have provided access to confidential material (collectively referred to hereinafter as the "Recipients"). The designation of confidential material shall be made by any practicable means, including placing on the thing so designated, such that it will not interfere with its legibility, an appropriate notice such as the following: "confidential" or "confidential material." Confidential material will be Bates stamped, if appropriate. All records and things designated as confidential material shall be treated as such pursuant to the terms of this Protective Order of Confidentiality until further order by the Court.

         5. The inadvertent, unintentional, or in camera production of any confidential material shall not, under any circumstances, be deemed a waiver, in whole or in part, of the confidentiality of the confidential material in question. If the Producing Party should inadvertently produce any confidential material not responsive to a formal request for production and/or an order of the Court, and/or inadvertently fail to redact confidential material not discoverable in this lawsuit, the Recipients shall immediately return the confidential material, including all copies or reproductions thereof, to the Producing Party, and shall make no use of the confidential material for any purpose until further order by the Court.

         6. Objection ...


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